NCS000222_SWPPP 2007_20070820

i
STORM WATER -DIVISION -CODING -SHEET
PERMIT NO.
rp 61)
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
❑ COMPLIANCE
A OTHER
DOC DATE
❑ lop-)0-5�-t-
YYYYMMDD

•
CAROLINA POLE LELAND,
INC.
0 STORM WATER
•
POLLUTION PREVENTION
PLAN
(SWPPP)
SWPPP 2007 Page 1 of 23

SCHEDULE OF REQUIRED ACTIONS/CHANGES
•
•
•
ITEM #
DATE
DESCRIPTION OF
ACTION/CHANGE
SCHEDULE
PERSON RESPONSIBLE
COMPLETED
001
8120107
Complete Update of
SWPPP (Old
SWPPP in files)
J. House, CHMM
CERTIFICATION STATEMENT
Certification Statement: I 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 gathered and evaluated the information submitted. Based upon 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 fine and imprisonment for knowing violations.
Name
Signature V--V'
Mike Rouse is the Facility
SWPPP 2007
Date Au-qust 20 2007
and kill sign the annual certification statements
Page 2 of 23

• STORM WATER POLLUTION PREVENTION PLAN
TABLE OF CONTENTS
w
1. GENERAL INFORMATION.........................................................................................4
2. POLLUTION PREVENTION TEAM...............................................................................6
3. DESCRIPTION OF POTENTIAL POLLUTANT SOURCES................................................7
4. MEASURES AND CONTROLS..................................................................................10
5. SPILL PREVENTION AND RESPONSE PLAN.............................................................14
6. PREVENTATIVE MAINTENANCE PROGRAM.............................................................15
7. FACILITY SECURITY................................................................................................15
8. NON -STORM WATER DISCHARGES...........................................................................15
9. SITE EVALUATIONSISAMPLINGIMONITORiNG..........................................................16
10. SITE PLAN INFORMATION........................................................................................17
11. EMPLOYEE TRAINING.............................................................................................18
12. FORMS.................................................................................................................18
SWPPP 2007 Page 3 of 23

GENERAL INFORMATION
40 1.a Purpose
The purpose of the SWPPP is to identify potential sources of pollution or contamination that originate at
this facility, and to select and implement actions which prevent or minimize the release of pollutants into
the storm water. The storm water management controls included in the SWPPP focus on providing
adequate control of pollutant discharges with practical approaches that utilize readily available
techniques, expertise, material and equipment.
The SWPPP is intended to be a flexible, active operations plan to allow incorporation of changes and
management practices. As the plan is implemented and methods to improve the plan are found,or as
regulations change, revisions to the plan must be made. Revisions to the plan must be approved by
management and recorded in all copies of the plan in order to meet the requirements of the storm water
permit.
This is a wood preservation facility. Logs and some untreated poles/cumber 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).
Forklifts 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.
• Gasoline/diesel unloading is performed in the yard near the treating plant on concrete. The
gasoline/diesel tanks are located inside secondary containment. 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.
BMPs currently in use are located under Section 4.
At this time, based upon a review of our current procedures for reducing or eliminating exposure of
materials to storm water, we have determined that our current BMP's are adequate for minimizing
exposure.
The maintenance area is inside a building, all oil tanks in secondary containment, all chemicals in
secondary containment or under cover. The untreated/treated poles and lumber stored outdoors, stacked
to minimize exposure and inventory controlled to reduce potential exposure to a rain event.
Housekeeping procedures are in place to regularly remove debris in the yard and inspect around our
maintenance and treating plant for chemical contamination.
1.b Procedural Requirements
The operator must comply with the following requirements:
• A signed copy of the SWPPP must be retained at the facility.
• The operator must conduct inspections at the facility in order to comply with the permit and this
plan. Inspection results may determine modification of this plan.
• The SWPPP will be updated whenever there is a change in design, construction, operation or
maintenance which may effect potential pollutants that may enter the storm water discharge.
• A copy of the permit will be kept with this plan
• All records must be maintained for at least one year from the date that the storm water permit
expires.
SWPPP 2007 Page 4 of 23

1.c Facility Information
Facility Mgr.
Michael Rouse Owner Name: Cox Industries
Facility Address:
1901 Wood Owner 860 Cannon Bridge Road
Treatment Road Address: Orangeburg, SC 29116-1124
Leland, NC
Facility Tel. #
[phone] Permit #: NCS000222
Primary SICINAiCS
24911321114 Permit February 28, 2005 (Renewal,
Renewal: submitted in July, 2004 - No new permit at
this time - New owner submitted in May.
2006)
Latitude
34 15 16 Longitude 078 04 28
Receiving Waters:
Cove Creek Runoff 0.74
Coefficient
Number of Outfalls:
Outfall Est. Est. Sq Ft. Coefficient Avg gals. Remarks
Acres per I" rain
001 128 5,575,680 0.821 2,853,391
Facility Total Acreage:
128 Acreage 2
graveled:
Acreage used for
80 Acreage paved: 0
Industrial Activity:
Acreage of
48 Acreage roofed: 5
undisturbed:
Process Description:
Wood preservation. Logs and some untreated 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. The
poles or lumber is placed into one of three cylinders and impregnated with a
wood preservative (chromated copper arsenate or Pentachlorophenol). Once
drippage has ceased, the treated poles or lumber is stored on the yard until
sold.
Liquid chemicals are stored inside concrete containment areas. Water that is
captured inside the chemical containment areas from rain events is re -used in
the wood preservation process. These containment areas cannot release
any liquid without manual pumping. Truck unloading of wood preservation
chemicals is within a tank truck containment area.
SWPPP 2007
Page 5 of 23

•
11
2. POLLUTION PREVENTION TEAM
Team Leader
Name
Michael Rouse
Title
Plant Manager
Responsibilities
Responsible for overall implementation of program. Ensures
implementation of plan with supervisors/employees. Ensure
inspections, sampling and BMPs in use. Determine effectiveness
of program. Incorporate changes based upon success or failure
of BMPs. May perform inspections. sampling. Performs periodic
review of plan.
Team Members
SW PPP 2007
Name I Bobby Russ
Title I Purchasing
Responsibilities Ensures implementation of plan with employees. May perform
inspections, sampling. Monitors BMP effectiveness. Assists with
implementing any changes or modifications to plan.
Name I Dale Bollinger
Title I Treating Supervisor
Responsibilities Ensures implementation of plan with employees. May perform
inspections, sampling_ Monitors BMP effectiveness. Assists with
implementing any changes or modifications to plan.
Page 6 of 23

0 0 0
DESCRIPTION OF POTENTIAL POLLUTANT SOURCES
3.a Risk Identification and Summary of Potential Pollutant Sources
Chemical or
Loading,
Operations
Outdoor
Outdoor
Particulate
On -site Waste Disposal
Pollutant Source
Unloading
Storage
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.
DiesellGasoline
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 piles 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
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 Process/Particulate 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
• Maim 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.
SWPPP 2007 Page 7 of 23

•
•
•
3.b Pollutant Information (Inventory of materials that may potentially be exposed to
precipitation)
Potential
Location of Potential
Reason for Potential
Management practices to
Outfall
Pollutant
Pollutant Source
Pollutant exposure to
minimize exposure to
Method of storage)
precipitation*
precipitation
Arsenic
Treating plant and in
Release from containment
Yard inspections, drip pad
001
treated poles/lumber on
area, yard drippage
under roof, chemicals inside
yard
containment
Chromium
Treating plant and in
Release from containment
Yard inspections, drip pad
001
treated poles/lumber on
area, yard drippage
under roof, chemicals inside
yard
containment
Copper
Treating plant and in
Release from containment
Yard inspections, drip pad
001
treated poles/lumber on
area, yard drippage
under roof, chemicals inside
yard
containment
Penta
Treating plant and in
Release from containment
Yard inspections, drip pad
061
treated poles/lumber on
area, yard drippage
under roof, chemicals inside
and
containment
Diesel
Treating plant, diesel
Release from containment
Yard inspections, drip pad
001
fueling area, and
area, yard drippage, fueling
under roof, chemicals inside
treated poles/lumber on
containment
yard
Oils
Maintenance shop,
Spillage, forklift leaks,
Daily forklift inspections,
001
stacker, loaders, trucks
stacker leaks
training, Maint. Shop and
Stacker indoors
Bark, chips,
Yard
Pole mill operation, framing
Frequent removal of sawdust
061
and
operation, misc. cutting of
to containers at framing yard.
Sawdust
poles/lumber
Pole mill bark/chips are piled
near boiler and away from
drainage areas — material
used in boiler. Frequent clean
up at pole mill
Boiler
Yard
Dirt residue from boiler clean
Piled in yard away from
001
Residue
out
drainage areas until disposed
of
SWPPP 2007
Page 9 of 23

�1
3.c Record Of Significant Leaks/Spills
If a significant leak/spill occurs, (such as a release that equals or exceeds a reportable quantity or if it is a
potentially harmful quantity, even though it is below a reportable quantity), then the SWPPP must be
modified within 14 calendar days. The modification will include a description of the release and the
circumstances leading up to the release. In addition we will review and identify any measures that may
be incorporated to prevent a reoccurrence. Any modifications will be added to the SWPPP.
DATE OF
SPILL,
LEAK
LOCATION
MATERIAL
INVOLVED
QUANTITY
OF SPILL,
LEAK
CAUSE/SOURCE OF
SPILULEAK
CLEAN UP
ACTIVITY
12/28/06
Treating
Pentachloro
< 1 lb
Supplier unloading hose
Washed area using
Plant
phenol
ruptured. Material sprayed
water. Water
Unloading
inside truck unloading bay.
placed into WWTU
(Truck) Bay
Less than 1 Ibs released
for recycling.
outside of containment area
4. MEASURES AND CONTROLS
The results of a site assessment indicate that controls are either in place or need to be added to minimize
contaminant releases to storm water run off. Housekeeping is one area that can be readily controlled to
limit the discharge of wood debris and minimize the generation of dust.
Best Management Practices (BMPs) as well as other controls are used to reduce potential contaminant
releases. Some of our controls are as simple as ensuring that we maintain vegetation, such as grass on
slopes to prevent soil erosion and keeping outfall areas clean and free of debris.
All chemical bulk storage tanks are within secondary containment and under roof. None of our secondary
containment structures have any type of drainage system that would allow a release into the yard. Only
personnel placing a pump into the diesel containment area can remove liquid. This method prevents any
release of oil from our containment system due to rain. Our chemical storage containment areas that are
not located inside a building have automatic pumps that will pick up liquid and place it into a bulk storage
tank located within a containment area. This liquid is then used in our treating processes.
Most hose as well as the trailer connections are inside a containment area or on concrete. If any tank or
hose connections would have to be outside the contained area due to an unusual circumstance, each
connection would have a bucket underneath to catch drips and minor leaks. A quaffied employee with
access to the proper safety equipment approves the hook up to our tank prior to unloading and monitors
the loading and unloading process.
All non -bulk containers, such as drums, are stored either indoors or within a contained area.
Finished pole/lumber products are stored in the yard until shipment. Prior to storing any treated pole or
lumber products outdoors, verification that there is no drippage has been documented (Ask to see
drippage reports).
The drip pad is under roof with a concrete base and metal secondary containment to prevent any release.
Any liquid generated from drippage or a rain event flows to a sump and then is automatically picked up
and place into an effluent tank. Visual, as well as some documented Inspections are regularly performed
on the drip pad and maintenance is performed as needed. (Ask to see any drip pad documented
inspection reports).
SWPPP 2007 Page 10 of 23

I*
All cutting of poles/lumber is currently performed outdoors. 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. 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.
Various types of equipment associated with this wood preserving facility include but are not limited to
pressure retorts, mechanical pumps, fueling trucks, maintenance equipment, freight transfer vehicles,
construction equipment and fork lifts.
Trucks, trailers, and forklifts are cleaned in an enclosed, roofed area designed for this purpose. The
water is reclaimed through an oil water separator.
It is recognized that maintenance of vehicles can be a significant source of storm water pollutants.
Materials associated with vehicle maintenance include waste oil, solvents and other degreasers, brake
fluid, anti freeze, battery acids, radiator flush, and sludge. The following vehicle maintenance practices
are utilized:
Maintenance is completed indoors and protected from runoff and precipitation whenever
possible. If maintenance has to be performed outside of the enclosed area, all possible
means are used to prevent spillage and approved cleaning methods (oil dry, etc) are used if
any spillage occurs.
All used products are properly stored until they are sent for recycling or disposal.
Batteries, used tired, and used solvents are collected and recycled through the appropriate
vendors (Typically batteries are recycled immediately, so there is minimal to no storage).
A feasibility review to determine if there is a way to modify or change our operating procedures or install
controls to further reduce chemical exposure indicates the following:
o Non -bulk chemical containment — All non -bulk chemicals are currently stored in secondary
containment areas or under roof.
o Chemical unloading — Chemical unloading is performed under roof or in containment areas that
will allow the end of the trailer to be placed within this containment. Most hose connections at the
tanks for bulk loading or unloading are inside the bulk storage containment area. Any tank or
hose connections outside the contained area would have buckets underneath to catch drips and
minor leaks. A qualified employee with access to the proper safety equipment approves the hook
up to our tank prior to unloading and monitors the loading and unloading process.
o Chemical containment — All chemicals are currently stored in secondary containment systems
that cannot release without manual pumping.
o Particulate containment — 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.
o Diesel storage — The diesel tanks used to fuel lifts and other equipment is located within a
secondary containment system that cannot release without manual pumping. Filling the tank and
fueling procedures are performed just outside the containment area on a concrete pad. This is all
under roof. Current procedures and training are in place to prevent a release on the ground as
well as emergency equipment availability at the diesel area to handle a release immediately to
prevent rain event contamination.
o Treated wood storage —Treated lumber is typically stored outdoors. Prior to placing the treated
lumber outdoors, the material is documented that all drippage has ceased. This procedure
should ensure that there is minimal release of chemicals during a rain event from the treated
lumber. The lumber is also not placed directly on the ground, but stored 2-6" above to prevent
contact.
SWPPP 2007 Page 11 of 23

To ensure that the BMPs and other controls are in use and working, employees are taught about controls
in use and periodic inspections are performed.
. The measures currently in use or to be implemented at our facility to control contaminant releases are
found under section 4.a.
s
4.a. Effective Pollutant control Options for Timber Product Facilities
Activity
Associated BMPs
In Use
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
Provide collection of runoff with containment basins,
sedimentation ponds and infiltration basins
Activity
Associated BMPs
In Use
Remarks
Residue Storage
Locate storage residues away from drainage pathways
X
Areas
and surface waters
(such as
Avoid contamination of residues with oil, solvents,
X
untreated
chemically treated wood, trash, etc.
sawdust, chips)
Assemble piles to minimize surface area of materials
X
exposed to precipitation
Limit storage time of residues to prevent degradation
X
and generation of leachates
Place materials on raised pads of compacted earth, clay,
shale, or stone to collect and drain runoff
Limit slopes of storage areas to minimize velocities of
X
runoff which may transport residues
Activity
Associated BMPs
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
SWPPP 2007
Page 12 of 23

•
•
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 runonlrunoff
Provide collection of runoff with containment basins,
sedimentation ponds and infiltration basins for treated
wood storage areas
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 oillwater
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
SW PPP 2007
Page 13 of 23

•
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
5. SPILL PREVENTION AND RESPONSE PROCEDURES
Spill prevention is key to preventing releases. Process controls are in place to minimize the potential for
a release and employees are trained on these process controls. All chemical storage tanks are located
inside containment areas. The containment areas cannot release any minor spills or drips unless liquid is
manually pumped out.
Facility personnel responsible for implementing the Spill Prevention and Response Procedures are as
follows:
o Mike Rouse — Facility Manager
o Scott Russell — Pole Mill Supervisor
o Palmer Matcher — Production Supervisor
o Dale Bollinger — Treating Supervisor
o Dale Nichols — Production Supervisor
c Jerry Faulk — Maintenance Supervisor
The above personnel perform visual and documented inspections of the facility's operational areas to
ensure there has been no damage to containment, equipment or releases due to chemical handling. At a
minimum, one of these personnel will be on site during operations.
Process controls in place to prevent a release are as follows;
o Daily visual inspections by above personnel and others to ensure there has been no accidental
releases
o Daily visual inspections of equipment by above personnel and others to ensure there are no leaks
o Weekly documented inspections of equipment and containment areas to ensure there have been
no releases or equipment leaks (Ask to see documented inspections)
o Chemicals are handled and stored on concreted, contained, and roofed areas
o Preventative maintenance program on forklifts, equipment, and containment to discover and
repair leaks, damage, or other issues that might cause a release
All personnel involved with the handling of hazardous chemicals or waste are trained under 40 CFR
265.16 and 29 CFR 1910.1200. Any large releases will be handled by an outside firm.
Information pertaining to a release and our response procedures are located in this facility's contingency
plan.
6. PREVENTIVE MAINTENANCE PROGRAM
This facility has a maintenance program. This program includes regular maintenance on all vehicles used
on site. Employees have been trained to notify the maintenance department or their supervisor if any
vehicles have a leak that needs repair. Daily visual inspections on all tanks and equipment that store
hazardous chemicals is performed by our operators to ensure prompt repairs for any leaks that may come
in contact with storm water run off.
SWPPP 2007 Page 14 of 23

Documented inspections on equipment is as follows:
o Weekly drip pad inspections to ensure no damage to drip pad or berm that may cause a release
. o Daily forklift inspection by operators
o Weekly equipment and storm water controls and discharge areas inspected weekly by
maintenance personnel.
o Periodic facility inspection, which includes outfall, containment, oil storage, and particulate
generating area inspections. This is performed at a minimum, 4 times annually.
40
All information pertaining to preventive maintenance for this facility are kept with the maintenance
supervisor or the facility manager.
7. FACILITY SECURITY
Security systems to prevent accidental or intentional entries that could cause a discharge are as follows:
Fencin Lighting
8. NON -STORM WATER DISCHARGE
8.a Authorized Non -Storm Water Discharges
Non -storm water discharges related to industrial activity that are authorized are below. Any other non -
storm water discharges are not permitted without not cation and authorization from the state.
Authorized by Regulation
Dischar es from fire fighting activities
Fire hydrant flushings
NA unless required by outside
reclulatorV personnel
Potable water sources, including water line
Rarely performed and usually
water is reused in processes.
Drinking fountain water
Two located on site. minimal water release,
does not discharge offsite unless rain event
Irrigation drainage
NA
Lawn Water
NA
Routine external building wash downs which do not use
detergents or other compounds
Infrequent (every 2-5 years)
Routine pavement wash waters where spills have not
occurred which do not use detergents or other compounds
Infrequent (cleaning small areas of
pavement once or twice a year)
Air conditioning condensate
Several buildings, minimal water release,
does not discharge offsite unless rain event
Compressor condensate
Several, minimal water release, does not
discharge offsite unless rain event
Uncontaminated springs
NA
Uncontaminated ground water
NA
Foundation or footing drains where flows are not contaminated
with processed materials
NA
SWPPP 2007
Page 15 of 23

C]
8.b Non -storm water discharges
The discharges from this facility are evaluated annually for the presence of non -storm water discharges.
The evaluation includes a visual inspection of each outfall during a non -storm event to determine any
releases.
Evaluation
Date
Non -storm water
discharges detected
Person Who
conducted Evaluation
Signature of Person who
conducted Evaluation
8120107
Visual inspection of
outfall shows no release
Jane House, CHMM
9. SITE EVALUATIONSISAMPLINGIMONITORING
Site evaluations/sampling and/or monitoring are performed based upon this facility's storm water permit.
9.a Sampling Requirements
Based upon our permit we are required to perform the following sampling. Sampling results are located
at the end of this plan.
Check
when
complete
MONITORING PERIOD
TYPE OF MONITORING
2005
January - March
Analytical one time Burin ear
April -June
Visual (qualitative)
Jul - September
October - December
Visual (qualitative)
2006
January - March
Analytical one time during ear)
April - June
Visual (qualitative)
Jul - September
October - December
Visual(qualitative)
2007
January - March
Analytical one time during year
April - June
Visual qualitative
Jul - September
October - December
Visual qualitative
2008
Janua - March
Analytical
April -June
Ana! ical/Visual Qualitative
Jul - September
Analytical
October- December
Analytical/Visual Qualitative
swPPP 2007
Page 16 of 23

0
•
•
ANALYTICAL REQUIREMENTS
VISUAL (QUALITATIVE) REQUIREMENTS
COD
Color
BOD5
Odor
Total Suspended Solids TSS
Clarity
Oil and Grease
Floating salids
H
Suspended solids
Copper
Foam
Chromium
Oil sheen
Arsenic
Other obvious indicators of pollution
Zinc
Pentachlorophenol
Phenol
Benzene
Toluene
Na thalene
Anthracene
Total Ammonia
Total X lenes
Total Phosphorus
TKN
OTHER REQUIREMENTS
Total rainfall precipitation of event sampled
Total duration of event sampled
Total flow of event sampled per outfall (calculated based on the
amount of area draining to the outfall, the amount of impervious area, and
the total amount of rainfall
Event Duration
Semiannual facility inspection of stormwater systems
9.b Sample Collection Protocols
Grab Sample Collection — A manual grab is collected within 30 minutes of a discharge at the outfall by
inserting a container under or down current of a discharge with the container opening facing upstream. If
the outfall is less accessible, then you may need to use a pole or bucket to collect the sample.
o Label sample containers before sampling
o Take a cooler with ice to the sampling point
o Take the grab from the horizontal and vertical center of the channel
o Avoid stirring up bottom sediments in the channel
o Hold the container so the opening faces upstream
o Avoid touching the inside of the container to prevent contamination
o Keep the sample away from uncharacteristic floating debris
o Use safety precautions
9.c Evaluations
Semi -Annual facility compliance evaluations are completed. These include an inspection of the outfalls
and a determination on whether our plan is effective. During this evaluation we will determine if any
changes to the plan need to be made. Results of these evaluations are located at the end of this plan.
SWPPP 2007
Page 17 of 23

10. SITE PLAN
• A copy of this facility's site plan is located at the end of this plan. Information provided on the site plan is
as follows:
s
• Chemical Storage
a Outfalls
• Lumber (Treated and Untreated)
• Fueling Stations
• Residue (Untreated)
• Loading/Unloading Areas
Maintenance
0 Run Off Flow Direction
Drainage areas for each outfall
Waste disposal areas
Drainage structures
• Activities occurring in each drainage area
Process areas
0 Potential pollutants
11. EMPLOYEE TRAINING
Employees that work at this facility will be trained periodically on Storm Water Pollution Prevention.
Training will include, at a minimum, the following information:
• What is Storm Water Pollution
• Sediment Erosion
• Treated Lumber, Ensuring No Drippage
Before Leaving The Drip Pad
• Housekeeping
• Best Management Practices in Use
• Forklifts - Oil/hydraulic leaks, fueling
procedures
• General Clean Up of Spills/Leaks
• Maintenance Work
Visual Inspections of Equipjment
Mike Rouse, or whomever he dictates, will provide the annual training.
All personnel involved with the handling of hazardous waste have been (or will be) trained under 40 CFR
265.16. All employees have received some training under 29 CFR 1910.1200 concerning the chemicals
located on site and basic spill/leak response procedures.
12. FORMS
Forms used for evaluations and inspections are as follows:
SWPPP 2007 Page 18 of 23

•
STORM WATER POLLUTION PREVENTION PLAN
ANNUAL CERTIFICATION
I CERTIFY, UNDER PENALTY OF LAW, THAT THIS DOCUMENT AND ALL ATTACHEMENTS 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, 1S, 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.
DATE PRINTED NAME
SIGNATURE
s
I CERTIFY, UNDER PENALTY OF LAW, THAT THIS DOCUMENT AND ALL ATTACHEMENTS 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.
DATE PRINTED NAME
SIGNATURE
�
I CERTIFY, UNDER PENALTY OF LAW, THAT THIS DOCUMENT AND ALL ATTACHEMENTS 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.
DATE PRINTED NAME
SIGNATURE
SWPPP 2007 Page 19 of 23

•
•
•
STORM WATER POLLUTION PREVENTION
SEMI-ANNUAL FACILITY SITE COMPLIANCE INSPECTION
NAME OF PERSON CONDUCTING INSPECTION DATE OF INSPECTION
Has your SWPPP been updated to include current Non -Storm Water
YES NO NIA
Discharge Evaluation results?
Has your SWPPP been amended for any new construction that would
YES NO NIA
effect the site map or drainage conditions at the facility?
Has your SWPPP been amended for any changes in facility operations
YE5 NO NIA
that could be identified as new source areas for contamination of storm
water?
Are there any materials at the facility that are handled, stored or
YES NO NIA
disposed in a manner to allow exposure to storm water that are not
currently addressed in your SWPPP?
Are outside areas kept neat and orderly?
YES NO NIA
Are regular housekeeping inspections made?
YES NO NIA
Do you see spots, pools, puddles, or other traces of oils, grease, or
YES NO NIA
other chemicals on the ground?
Are particulates on the ground from industrial operations or processes
YES NO NIA
being controlled?
Do you see any leaking equipment, pipes or containers?
YES NO NIA
Do drips, spills, or leaks occur when materials are being transferred from
YES NO NIA
one source to another?
Are drips or leaks from equipment or machinery being controlled?
YES NO NIA
Are clean up procedures used for spilled solids?
YES NO NIA
Are absorbent materials (floor dry, kitty litter, etc.) regularly used in
YES NO NIA
certain areas to absorbs ills?
Can you find discoloration, residue, or corrosion on the roof or around
YES NO NIA
vents or pipes that ventilate or drain work areas?
Are Best Management Practices implemented to reduce or eliminate
YES NO NIA
contamination of storm water from source areas at the facility?
Are Best Management Practices adequately maintained?
YES NO NIA
Are there significant changes that will have to be made to your SWPPP to
YES NO NIA
correct any inadequacies that the plan may have to effectively control a
discharge of contaminated storm water from your facility?
Are outfall locations clean and free of debris?
YES NO NIA
Any signs of erosion on the property site?
YES NO NIA
Are all bulk tank containment areas in good condition, no sign of damage
YES NO NIA
and no contamination outside of containment areas?
Swale areas in good condition?
YES NO NIA
Ditch areas in good condition, not overgrown or damaged?
YES NO NIA
If any of the ditches require maintenance, circle the type(s) needed
Sediment removal
Mowing
Re -vegetation of side slopes
Erosion area repair
Debris removal of pondloutlet
REMARKS:
SWPPP 2007
Page 20 of 23

GRAB SAMPLE FORM
. LOCATION: 001
a
•
DATE;
RAIN EVENT START TIME: DISCHARGE START TIME:
GRAB SAMPLE COLLECTION
TIME OF
COLLECTION
FLOW DEPTH AT
OUTFALL
RAINFALL GAUGE
READING
pH
RAIN EVENT INFORMATION
TIME EVENT
STOPPED
DURATION OF RAIN
EVENT (HOURS)
RAINFALL GAUGE
READING
TOTAL RAINFALL
(INCHES)
ESTIMATED TOTAL RAIN EVENT RELEASE FROM SITE
2,853,391 gallons per
one inch of rain
incises x 2,853,391 gallin = gals. Rel
SAMPLING PERSONNEL
Frequency of
Sampling
Ouffaiis to
Sample
Type of
Sam tin
Analytical Requirements..
See SWPP Plan
001
Grab
COD
Pentachloro henol
BOD5
Phenol
Total Suspended Solids `TSS
Benzene
Oil and Grease
Toluene
H
Na thalene
Copper
Anthracene
Chromium
Total Ammonia
Arsenic
Total Xylenes
Zinc
Total Phos horus
SWPPP 2006
Page 21 of 23

9
•
STORM WATER POLLUTION PREVENTION
SEMI-ANNUAL VISUAL (QUALITATIVE) INSPECTION REPORTS
OUTFALL
NUMBER
2007
APRIL-JUNE
OUTFALL 001
2007
SEPT-NOV
OUTFALL 001
2008
APRIL-JUNE
OUTFALL 001
2008
SEPT-NOV
OUTFALL 001
2009
APRIL-JUNE
OUTFALL 001
2009
SEPT-NOV
OUTFALL 001
INSPECTOR
DATEITIME
COLOR
ODOR
CLARITY
FLOATING
SOLIDS
SUSPENDED
SOLIDS
FOAM
OIL SHEEN
OTHER
OBVIOUS
INDICATORS OF
POLLUTION
J = Indicates no problems X = Indicates contamination (Nate probable sources of any observed storm water contamination)
'Observations to note: Color, odor, turbidity, floating solids, foam, oil sheen, or any other Indications of storm water pollution. Note the probable sources of any observed
storm water contamination.
"Observations should be made within first 30 minutes of precipitation, but no later than 60 minutes in daylight and when sufficient runoff occurs.
SWPPP 2006 Page 23 of 23

•
•
INCO
Leland, NC
INTEGRATED
Carolina Pole — Leland, NC Contingency Plan Page 1 of 13
2006

This Contingency Plan meets requirements of 2NCAC9L.1900
Inspectors Signature
Date
Inspectors Signature
Date
Inspectors Signature
Date
INTEGRATED HAZARDOUS MATERIALS & WASTE CONTINGENCY PLAN
TABLE OF CONTENTS
FACILITY INFORMATION
EMERGENCY RESPONSE CONTACTS
TEAM MEMBERS AND JOB DESCRIPTIONS
MEDICAL INFORMATIONIPROGRAM
SITE INFORMATION
OVERVIEW OF FACILITY OPERATIONS
INCIDENT HISTORY
EVACUATION PROCEDURES
GENERAL FIRE PROCEDURES
GENERAL SPILL/EMERGENCY RESPONSE
® PROCEDURES
EMERGENCY EQUIPMENT
DECONTAMINATION
DOCUMENTATION OF INCIDENT
PERSONNEL TRAINING
INSPECTIONS
SECURITY
COMMUNICATION PROCEDURES
PREVENTION & BEST MANAGEMENT
PRACTICES
NATURAL DISASTERS
APPENDIX
DECONTAMINATION LAYOUT
HAZARDOUS MATERIALS STORAGE
LOCATIONS AND REPORTABLE QUANTITIES
FACILITY SITE PLAN
FIRE FIGHTING TACTICS FOR PESTICIDES
• TANK LAYOUT
................................................................... 3
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................................................................... 4
.................................................................. 4
................................................................... 4
.................................................................. 5
................................................................... 5
................................................................... 5
................................................................... 5
................................................................... 6
................................................................... 7
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Carolina Pole - Leland, NC Contingency Plan Page 2 of 13
2006

INTEGRATED HAZARDOUS MATERIALS & WASTE CONTINGENCY PLAN
•
0
FACILITY INFORMATION
Facility Name Carolina Pole Leland, Inc. Telephone # [phone]
Location Address 1901 Wood Treatment Rd Fax # [phone]
Leland, NC 28451
Mailing Address P. O. Box 370 EPA I.D. # NCD093137636
Leland, NC 28451
County Brunswick SIC Code 2491
Facility Lat— 34 15 16 NAICS 321114
Latitude/Longitude: Long— 078 04 28
Directions to Facility: Going 74 West past the 2''d Leland Exit (past Leland Industrial Park). Sign on left
side of road says 'Carolina Pole" 141711 have to turnaround to enter facility.
Primary Emergency Coordinator Secondary Emergency Coordinator
Name:
Mike Rouse
Name:
Dale Bollinger
Address:
2001 Bonner Bussells Drive
2089 East 53
Southport, NC 28461
Kelly, NC 29448
Telephone #:
[phone] (Horne)
Telephone #:
[phone] (Home)
[phone] tCell)
[phone] (Cell)
The Primary and Secondary Emergency Coordinators are authorized to spend company funds in the event of an
emergency.
EMERGENCY RESPONSE CONTACTS
Local
State
Fire Department
911
Environmental Quality Dept.
[phone]
of North Carolina
[phone]
Ambulance Service
911
Federal
Environmental Protection
[phone]
Agency Region 4
Sheriff's Department
911
Brunswick Count
[phone]
National Response Center
1-800-424-6802
Emergency Mgmt.
NC Dept of Agriculture
[phone]
Arch Chemicals Emergency
[phone]
Action Network (ACEAN)
Copies of this contingency plan have been given to the following outside support groups to assist in the event of an
emergency:
Sheriff's Department— To provide traffic and crowd control during an event, as well as assist in overseeing any
ambulance services necessary for injured personnel.
Emergency Management'Fire Department— Respond to any fires located on the site. It is also expected that the
Emergency Management Coordinator will bring in their hazardous materials response team to provide assistance in
stopping a chemical release and preventing any materials from leaving the property site.
New Hanover Regional Medical Center- The hospital is expected to provide triage and any medical services for
injured personnel brought in due to an event at our facility.
•NCDENR — The state is expected to provide technical guidance during and after an incident that may affect the
environment.
Carolina Pole — Leland, NC Contingency Plan Page 3 of 13
2006

TEAM MEMBERS AND JOB DESCRIPTIONS
A decision has been made to only have employees provide minimal/defense or no response to emergency situations.
The following contractor will be used for response and/or cleanup. We do not currently have a contract with any
.emergency response services, but the following company is local and may provide services after the Fire Department
HAZMAT team has completed its response.
Southeast Response & Remediation, Inc.
Wilmington, NC
[phone]
MEDICAL INFORMATION/PROGRAM
The local Physician and Hospital below have a copy of this plan along with Material Safety Data Sheets for all of our
major chemicals to use in the event of an injury, exposure or medical emergency.
PHYSCIAN
North Brunswick Family Medicine
117-H Village Road
Leland, NC
371-0404
HOSPITAL
New Hanover Regional Medical Center
2131 S. 17r" Street
Wilmington, NC
[phone]
Employees are not qualified to perform any rescues on personnel located in a potentially hazardous environment
due to a spill, leak or fire.
If a rescue is necessary, the fire department will be notified to provide rescue and emergency services.
Several employees may have been trained in first aid and CPR procedures. However, it is not in any job descriptions
that employees must perform first aid duties_ Any medical assistance would be voluntary.
SITE INFORMATION
Within a Y2 mile radius of this facility:
• Industrial: Vic Taulic Hydraulics, Industrial Pump Service
• Residential: None — Population estimated at less than 500
Schools: None
• Soil Type: Mandarin fine sand.
Waters: None within 1 to 1.5 miles
• Surrounding Only on North side of facility are any industrial sites (See Industrial for list). These
Occupancies & sites are located past a small woodland area and railroad tracks. Forest surrounds
Land Use: the South, East, and West sides.
The nearest stores to purchase items are:
Company: Bame Ace Hardware & Lumber
Address: 117 B Village Road
Leland, NC
Telephone #: [phone]
OVERVIEW OF FACILITY OPERATIONS
This facility involves wood preservation of utility poles and piling. Wood preservatives are impregnated into wood by
pressure treatment in cylinders. Operations include: Treating plant using Pentachlorophenol and Chromated Copper
Arsenate wood preservatives; wastewater treatment system; Two Pole peelers, Dry Kiln; Boiler, Maintenance Shop.
Carolina Pale - Leland, NC Contingency Plan Page 4 of 13
2006

INCIDENT HISTORY
There have been no spills or releases within the last five years from the date on this plan.
. EVACUATION PROCEDURES
Evacuation location: Grassy area in front of main office
Weather related evacuation: Main Office - Center Room; Treating Plant - Under Office; Boiler - Office
Manage Evacuation
Mike Rouse
Oversee Evacuation
Jerry Faulk
Plan:
of the Maintenance
area:
Oversee Evacuation
Mike RouselSobby Russ
Oversee Evacuation
Dale Nicholas/Alton Stanley
of the Office Location:
of Framing and West
Yard area:
Oversee Evacuation
Dale Bollinger/Robert
Oversee Evacuation
Scott RusselUCollis
of the Treating Plant
Bollinger
of Pole Mill and East
Graham
Location:
Felton Graham (Night)
yard Area:
Emergency
Mike Rouse/Dale
Oversee Evacuation
Palmer Hatcher/James
Assistance
Bollinger
of Boiler Area:
McMillan/Allen
Notification:
Maragne/Roscoe Maye
Visitor Log and Radio
Mike Rouse/Palmer
Notification:
Hatcher/Dale Nicholas
*Senior management officials will determine any outside notifications necessary and/or ensure that these are completed.
Personnel Notification of an Emergency
This plan will be instituted anytime the emergency alarm system goes on,
whether manually or automatically. Below are some (tut not all) of the potential emergencies that may occur at this
® facility.
• Fire
Severe chemical spill or leak
Person seen or found unconscious for an unknown reason
Evacuation routes are posted through out this facility.
This facility does not have an alarm system. Notification of an emergency to all personnel will be on radio.
Emergency Equipment Shutdown Procedures
Emergency shut down procedures are required for the following equipment only if it can be done without planing anyone
in danger:
Treating cylinders. If one or more of the treating cylinders are running a cycle, then
pumps may need to be shut down, valves closed and pressure removed from the
cylinder prior to evacuation to prevent a spill.
Boiler may need to be shut down.
Accounting for Personnel after Evacuation is Complete
The listed personnel will determine that all visiting employees have been accounted for.
Department supervisors will determine that ail employees have been accounted for.
Carolina Pole - Leland, NC Contingency Plan Page 5 or 13
2006

GENERAL FIRE PROCEDURES
Small fire —Fire extinguishers are kept in several locations throughout the facility. In the event of a small fire, select
employees have been trained in the use and handling of the fire extinguishers.
Large Fire - all employees are to evacuate. The local fire department will be notified to handle this type of emergency,
Water is available on site for the fire department to use.
Note:Evidence shows that the smoke from fires involving CCA treated lumber is not significantly more toxic than
untreated lumber. ALSO ashes from treated lumber may contain arsenic, copper, chromium, and pentachlorphenol.
GENERAL SPILLIEMERGENCY RESPONSE PROCEDURES
ONLY EMPLOYEES THAT HAVE BEEN TRAINED ARE ABLE TO CONTAIN, STOP LEAKS OR PERFORM CLEAN
UP. ALL OTHER EMPLOYEES ARE ONLY AUTHORIZED TO NOTIFY MANAGEMENT
ALL REQUIRED PPE MUST BE DONNED PRIOR TO RESPONDING TO ANY SPILLS.
Liquid spill in a contained area — For all water soluble chemicals, the hazardous chemical can be washed down to the
nearest sump and then picked up and placed back into the effluent system for re -use in the process.
For non -water soluble chemicals (such as Diesel fuel), an absorbent will be placed over the spill area to pick up the
chemical. After the maximum amount of chemical has been picked up, the area will be cleaned and mopped using a
mild detergent. The material will be stored in sealed, labeled, compatible drums or buckets and disposed of according
to State and Federal Regulations.
Liquid spill in a non -contained area — For all chemicals, the following procedures apply:
Safely stop the flow, if possible
Contain the spill by building a dam type, U-shaped structure using sand, kitty litter, lime or dirt. The containment
structure should be built back far enough away from the spill to allow time for complete containment
Notify the proper authorities lithe amount of chemical released was at or above the reportable quantity. (This
should be done As Soon As Possible and immediately if the spill has left the property)
Once contained, inspect the area to ensure that the release did not leave the properly. If the release left the
property site, notify the local and state emergency contacts. Prevent any further quantity of the chemical from
leaving the property. Have a topographical map available to assist in determining the flow pattern of the released
chemical. (At the Treating Plant, where the bulk chemicals are stored, the closest property edge is greater than 500
feet before these products can leave the property.)
Pick up any liquid using a wet/dry vacuum system or pump. This liquid goes back to a containment area for re -use
or is properly stored for disposal. Diesel Fuel and/or other chemicals will be picked up using absorbents if
vacuuming or pumping is not feasible.
• Dig up the contaminated dirt a minimum of 2-4 inches. Store in properly sealed, labeled, compatible drums. All
products in bulk are compatible with steel drums with a painted liner.
• Sample the area after cleaning to determine that all of the contaminated soil has been removed.
Solid chemical spill in a contained area - The spill will be swept or vacuumed up and placed in properly sealed,
labeled and compatible drums or buckets for re -use or approved Federal and State disposal.
Solid chemical spill in a non -contained area - The spill will be swept, shoveled or vacuumed up and placed in
properly sealed, labeled and compatible drums or buckets for re -use or approved Federal and State disposal. The top
layer of contaminated soil will be removed and placed into property sealed, labeled and compatible drums for approved
State and Federal disposal. Sample the area after clean up to ensure that all contaminated soil has been removed.
GENERAL SPILUEIVIERGENCY RESPONSE PROCEDURES CONTD
Gas, fume or vapor releases into the atmosphere — Most of the chemicals kept at the facility generate minimum to no
vapors or fumes, except in a fire situation. Diesel Fuel, gasoline, and propane may represent a potential fiammability
vapor hazard. The exposure levels are as follows:
Hazard
LEL
UEL
Vapor Density
Diesel fuel
0.9%
7.0%
3-4
Gasoline
1.3%
6.0%
3-4
Propane
2.3%
9.5%
1.56
Carolina Pole— Leland, NC Contingency Plan Page 6 of 13
2006

The vapor will remain close to the ground, if a quantity greater than 50 gallons of any of the above is released, electrical
equipment within a 100 foot radius will be shut down and the local fire department notified.
•
•
G
EMERGENCY EQUIPMENT
The following spill/response equipment is available:
Equipment
Location
Purpose
Portable Pumps
Treating Plant/Maint Shop
Transfer of Material
Speedi-Dry
Maint Shop
Absorbent
Shovels
Treating PlanUMaint Shop
Containment and container filling
Absorbent boom
Maint Shop
Containment
Absorbent Pads
Maim Shop
Absorbent
Lime
Near Tank Farm
Neutrafizing and absorbent
Marl
Near Tank Farm
Containment and stabilizing
Earth
Beside Boiler room
Stabilizing
Shavings
Boiler Room
Absorbent
Drums/boxes/etc.
Near Tank Farm
Storage of material picked up
PPE (Gloves, etc.)
Treating Plant/Maint Shop
Employee protection
Earth Moving Equipt.
Maint Shop
Containment
Water
Treating Plant/etc.
Eliminate Fire
DECONTAMINATION
A decontamination area will be set up using the following equipment:
• Plastic baby pool (one for wash, one for rinse)
• Roll of plastic to lay down under the decontamination area
• Scrub brushes
• Cleaner for removal of diesel fuel
Plastic will be laid down to form a path from the spill area (under the decontamination area) to the "dean" area to
prevent the spread of contamination. Equipment and personnel wiR use the water from the pool to clean equipment. All
equipment, once cleaned will be returned to the treating plant area. Any disposable items will be cleaned and thrown
away into the clean trash or, if not cleanable, will be placed into drums and
disposed of according to State and Federal regulations. If diesel fuel or other "oily" product is involved, a cleaning aid
will be added to the water_
Once completed, the water will be pumped back to the treating plant for re -use. If the liquid cannot be re -used, then it
will be drummed and disposed of according to State and Federal regulations. (See attached diagram)
DOCUMENTATION OF INCIDENT
Documentation will be kept in a file that is located in the office. Information included is as follows:
Weather Conditions
Time
Details on control of incident (containment/dean
up)
Measures taken to prevent future incidents
Agencies Notified
See the form used in the back of this plan.
Carolina Pole — Leland, NC Contingency Plan
2006
• Date
• Product
• Investigation information on how accident
occurred
e Whether incident was recordable
• Agencies to receive written report
Page 7 of 13

PERSONNEL TRAINING
All personnel involved with the handling of hazardous waste have been (or will be) trained under 40 CFR 265.16. All
employees have received some training under 29 CFR 1910.1200_ Any personnel that will be involved in an emergency
• response incident has training in the following areas:
Hazardous chemical properties for on site + Hazardous waste training (40 CFR 265.16)
chemicals (29 CFR 1910.1200)
Personal Protective Equipment to use • Emergency equipment and its usage
Spill/leak containment + Hygiene procedures
Decontamination procedures • Contingency plan
Appropriate phone call procedures
Training will be per OSHA's HAZWOPER training requirements under 29 CFR 1910.120
0
•
An emergency response is defined as a release that requires personnel to be pulled from other departments to assist.
INSPECTIONS
• Weekly inspection of Drip pad containment area to ensure there is no leakage
• Monthly inspection of the entire facility, including emergency equipment and the security fence
• Weekly inspection of Hazardous waste storage area
• Daily visual inspections by treating operators
SECURITY
Due to the relatively small work force, employees know all others that work at this facility. Visitors entering the plant
must check in at the office. Employees have been told to question any personnel on the plant site that are not with
another employee or are unfamiliar.
Security systems in place are as follows:
Phone System:
Phones are located in the office, lab, treating room, maintenance shop,
boiler room, scale house, and guard shack. Interplant communication is
available on al! phones. Phones from all locations, except the scale
house, are available for extemal communication. Phones are used on a
daily basis and any malfunctions are reported for prompt repair.
Portable Radio System
A portable radio system is maintained with all supervisors plus the lab
and office have units. Radios are used daily. Two spare units are
maintained in order to keep working units available during repair.
Entrance Gate:
The entrance to the plant has a steel gate, which is kept closed when
the plant is not in operation.
Personnel:
At least one employee, and typically two or more employees are on site
24 hours a day, 7 days per week. Approximately 2-4 weekends per
year, the boiler is shut down and personnel are not required During
these infrequent times, the entrance gate is closed and locked.
Lighting:
Lighting has been installed through out the facility to reduce vandalism.
Carolina Pole — Leland, NC Contingency Plan
2006
Page 8 of 13

COMMUNICATION PROCEDURES
The senior employee on site at the time of the accident will initially notify the primary or secondary coordinator and
inform them of the following;
• Chemical spilled
• Estimated quantity
• Location of spill
• Any injuries
• If the spill leis the property site
• If the spill has been contained
The primary or secondary coordinatorwill notify the proper authorities if necessary
On site communications is verbal, radio or by telephone
PREVENTION AND BEST MANAGEMENT PRACTICES
This facility
• Weekly inspections of the drip pad area
• Weekly hazardous waste storage area
• Monthly full facility inspections
• Bulk Chemicals are kept in contained (diked) areas
• Periodic training on handling and spill control of the chemicals on site for employees
• Initial forklift training and continued evaluations
• Daily visual inspections of chemical storage equipment by employees prior to use
• Maintenance program which includes immediate repairs of equipment that shows signs of leakage
Unloading of bulk liquid chemicals are done by trained professional drivers on concreted or asphalted areas
using buckets at each hook up point that is not in a contained area. Spill equipment is immediately available
and with the driver.
is NATURAL DISASTERS
•
A natural disaster pertains to a threat to the operations or equipment as related to severe and unusual weather
conditions. Examples of such weather conditions include, but are not limited to; hash flooding, snow/ice storms, tornado
or high winds, Hurricanes, severe cold.
The best defense against these events is early warning. With advance notice from a radio, we can plan to minimize a
natural disaster impact with the following preparations:
• Orderly plant shutdown, which includes valve closures and/or pipe draining to prevent breakage
• Stocking of extra absorbents and other items that might be needed in the event of a problem
• Moving of potential problem chemicals (small quantities) into more secure areas,
Our goal is to always be proactive in preventing potential problems due to natural disasters by maintaining emergency
equipment inventories, anticipating problems through inspections, and quality training. In the event of a tornado or other
type severe weather, employees will be directed to designated locations within their departments for shelter. (See
Evacuation Section for more information).
Carolina Pole - Leland, NC Contingency Plan Page 9 of 13
2006

DECONTAMINATION LAYOUT
0
0
PLASTIC
WASH POOL
RINSE POOL
CLEAN DISPOSAL
CAN
Carolina Pole — Leland, NC Contingency Plan
2006
(SPILL L OCA TION)
(CLEAN AREA)
DOUS
vv.y�a � DISPOSAL
CAN 0
Page 10 of 13

CAROLINA POLE LELAND INC.
(FORMERLY GENERAL WOOD PRESERVING, INC.)
1901 Wood Treatment Road
Leland, NC 28451
. [phone]
•
DIRECTIONS: 74 West past the Leland Exit, Sign on lets says "Carolina Pole"
Name & Telephone # of Person
Reporting Release:
Evacuation Required?
Yes No
Date/Time of Release
Name of Chemical(s) Released:
Location of Release:
Approximate Quantity
Released:
What was affected by Release?
Soil Water Air Other
Any Injuries due to Release?
Yes No #
Any damage due to
Release? Yes No
Current measures in use to
stop the release:
Internal Notification to Whom?
(include time of notification)
External Notification to what
Agencies?
(Include time of notification}
Weather Information:
Other Information:
Carolina Pole — Leland, NC Contingency Plan
2006
Page 11 of 13

•
HAZARDOUS MATERIALS STORAGE INFORMATION
Product Name
Hazards
Location
Reportable
Type Of
Gallons in
Bulk Storage
Secondary
Quantity
Containers Or
container or
Construction
Containment
Tanks
tank
Materials, Year
(Concrete With
Built
Curbing)
Chromated
Poison
Treating Plant
>1/2 gal
Bulk Tank #23
4,885
Steel — 20+ yrs
Yes
Copper Arsenate
(7.5 Ibs)
60% Concentrate
Solution
CCA Work
Poison
Treating Plant
>6.7gallons
Bulk Tank #4
40,290
Steel — 20+ yrs
Yes
Solution 7.5%
60.3 Ibs
CCA Work
Poison
Treating Plant
'27gallons
Bulk Tanks # 5,
29,930 gals each
Steel — 20+ yrs
Yes
Solution 2.3%
227 lbs
6,7
CCA Effluent
Poison
Treating Plant
*54 gallons
Bulk Tank
Solution
Pe nta chloro phenol
Poison
Treating Plant
Bulk Tank #10
20,929
Steel — 20+ yrs
Yes
40% Concentrate
Combustible
Penta Mix Tank
Poison
Treating Plant
Bulk Tank # 30
29,594
Steel --18+ yrs
Yes
Penta Work
Poison
Treating Plant
Bulk Tanks # 1,
40,290 gals each
Steel — 20+ yrs
Yes
Solution 7.5%
2
Potassium
Wastewater
Bulk Tank # 29
26,762
Steel -
Yes
Permanganate
Plant
Feed Tank
Hazardous Waste
Poison
Treating Plant
1 pound
Drums (Max 24),
Drums = 55 gals
NA
On concrete, no
cardboard boxes
Boxes = 100 gals
berm
(Max 24) or bulk roll
Bulk = 20 cubic yds
off Max 1
Gasoline
Flammable
Yard or Maint.
25 Gallons; sheen;
from
�uik
DD D
Shop<100'
water
i
Diesel Fuel #2
Combustible
Treating Plant
25 Gallons; sheen;
Bulk Tank
2,500
Steel —15+ yrs
Yes
<1 W from water
Hydraulic Oil
Irritant
Treating Plant
25 Gallons; sheen;
Bulk Tank x 2
550 gals each
Steel — 10+ yrs
No — Tanks are
<100' from water
Double containment
Waste water
Misc. tanks used to separate penta/oil from water. List is located under Appendix "
Yes
treatments stem
HAZARDOUS WASTE TSD FACILITY
Name
Clean Harbors Reidsville LLC
Address
208 Waflington Industrial Drive
Reidsville, NC 27320
Telephone #
[phone]
EPA ID #
NCDO00648451
Carolina Pole — Leland, NC Contingency Plan Page 13 of 13
2006

0
0
0
Map Source: USGS Topographic Map Winnabow, North Carolina Quadrangle 1990
0 2000' 4000' ffMACTEC
APPROX. SCALE IN FEET
SITE LOCATION MAP DRAWN: KAT DATE: 6/29/04
GENERAL WOOD APPROVAL; JCP SCALE: AS SHOWN
HIGHWAY 74176 JOB M 6470-03-0500 FIG. NO. 1
LELAND, NORTH CAROLINA

U8 HWv - -
Ws WATER SUPPLY pWELL t :� CouerzCQ 0�.� > > ck I n S
�-�
X Aian,�a":L"A-r1 I C) Z h
GRAPHIC SCALE - IN FEET
0 400 800
U
SITE MAP Co olTA VoIQ, LdAn4 M A C T EC DRAWN: WBM JOB: 6470-03-0500
GENERAL WOOD FACILI APPROVAL: JCP DATE: 6/29/04
LELAND, NORTH CAROLINA
SCALE: AS SHOWN FIG: 2
•

•
0
0
HAZARDOUS MATERIALS STORAGE INFORMATION
. ... ... . ... .................................
Secondary
Product Name Hazards Location Reportable Type Gallons in Bulk Storage
Quantity Containers Or container or Construction Containment
Tanks tank Materials, Year (Concrete With
Built Curbing)
..... . . .... ..... . ...... .. - - -------------
Chromated Poison Treating Plant >112 gal Bulk Tank #23 4,885 Steel - 20+ yrs Yes
i,,Uppel tAlbe1141,e
1
Z) rut,)
60% Concentrate
Solution
.. . .......... . I ­ ................... . . . . . .
CCA Work
. . .......... . ........
Poison
. . ......... . ......... . . . . ....
fneatiflg Plant
...... . ..... . . .... . ...........
>6.7gallon5 B 11k T3 nk #4
l 40,25
Solution 7.5%
. . . .......... ........ . ....
(60.31
CCA Work
Poison
Treating Plant
*27giiillons Bulk Tanks i
2�9 9
Solution 2.3%
CCA Effluent
Poison
Treating Plant
_6,7 . . .
*54 gallons Bulk Tank
. . ....... ... ... ..... . .................. .
,--Solution
-------
Pentachlorophenol
Poison
Treating Plant
Bulk Tank #10
20,9:
40% Concentrate
Combustible
i
nta Mix Tank
Poison
Treating Plant
Bulk Tank # 30
1 29,5'
Penta Work
Poison
Treating Plant
tBulk _Tanks #_ 17
40 , 2!
Solution 7.5%
2
Potassium
VVastewa_te_r_­.
Bulk Tank# 29
26,71
Permanganate
I
Plant
Feed Tank
Hazardous Waste-
_P o i _so_n
Treating Plant 1 Drums (Max 2df.
pound cardboard boxes
Drur�<
Boxes
(Max 24) or bulk roll
Bulk
off (Max_11.._
Gasoline
Flammable
Yard or Maint.
125 Gallons. sheen:
Shop
<100, from water
Diesel Fuel #2
Combustible
Treating Plant
25 Gallons: sheen: j Bulk Tank
2,501
Hydraulic; Oil
-100' from water
Irritannt Treating Plant 25 Gallunt,, sheen, Bulk Tank x 2 550 1.
<1 00'frorn water
Misc used to separate pentaloil from water. List is located under App
Waste water
treatment system
... .............................................. .... ........................................................
)0 Steel - 20-+ yrs Yes
10 Qqls each Steel - 20+ yrs Yes
..... .. . .. ... .......................
!9 Steel - 20+ yrs Yes
14 Steel - 18+ yrs Yes
10 gals, each Steel - 20+ yrs Yes
i 2 Steel - Yes
HAZARDOUS WASTE TSD FACILITY
Name Clean Harbor: Reidsville LLC
Address 208 Wattingtoti lodustrial Drive
Reidsville, NC 27320
Telephone # [phone]
EPA ID # NCD000648451
Carolina Pole — Leland, NC Contingency Plan f!
2006