NCS000552_Staff Report Request to RO_20120620

NCS00552
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Anderson Land & Timber Company, LLC
NPDES Permit Number:
NCS000552
Facility Location:
127 Buck Seaford Road, Mocksville, NC (DAVIE County)
Type of Activity:
Sawmill and Wood Treating Operation
SIC Code:
2421
Receiving Streams:
Unnamed Tributary to Bear Creek (Figure 1)
River Basin:
Yadkin -Pee Dee River Basin, Sub -basin 03-07-06
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Response Requested by (Date):
July 20, 2012
Central Office Staff Contact:
Return to: BETHANY GEORGOULIAS, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 hard
Compliance history
6
Benchmark exceedance
Cannot Rate
Location (TMDL, T&E
species, etc)
3
Other Challenges:
• Impairment
8
Difficult Rating:
Cannot Rate/40
Special Issues Explanation:
o Stream is impaired for biological integrity and copper. This facility uses a wood treatment
solution that contains copper.
o Previously under NCG210172; being moved under an individual permit.
Description of Onsite Activities:
• Lumber yard with planar mill, chip mill, lumber separator, wood treating operations, drip pad,
and wood storage areas.
• Company uses ACQ (Alkaline Copper Quaternary) solution, with copper and ammonium
chloride to treat lumber.
• See application for further details.
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NCS000552
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU and Central Files (NCG210172)
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2010 final and 2012 draft
• 2008 Yadkin Pee -Dee Basinwide Plan
History:
• Date permit first issued: N/A, new individual permit. Covered under General Permit No.
NCG210172 since 1998.
• May 3, 2011: Winston-Salem Regional Office notified permittee that facility was under the wrong
permit. NCG210000 excludes wood treatment operations. Instructed permittee to submit an
individual stormwater permit application.
Figure 1: Map of Facility
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NCS000552
Central Office Review Summary:
1. Owner's Other Permits:
• NCG210172 will be rescinded upon issuance of this individual NPDES stormwater permit.
2. General Observations:
Winston-Salem Region Inspection Report from May 3, 2011 documented that the facility had not
developed an SPPP or performed the required analytical or qualitative monitoring. This facility was
directed to apply for an individual stormwater permit because it was a wood preserving operation.
Impairment: Bear Creek is impaired for copper and biological integrity. This facility uses a wood treating
solution that contains copper.
4. Threatened and Endangered: Per Judy Ratcliffe, NHP on 6/20/2012: No concerns in or within a mile of
the area (see correspondence records).
5. Location: This facility is located in the Yadkin -Pee Dee river basin, in the sub -basin that includes the
South Yadkin River and its tributaries. The 2008 Basinwide Plan cites agriculture and impervious
surface/stormwater runoff as potential contributing factors to the impairment of Bear Creek.
6. Industrial Changes Since Previous Permit: The facility switched from CCA (chromated copper arsenate) to
ACQ (alkaline copper quaternary) in 2003/2004.
7. Analytical Monitoring Notes: No analytical monitoring available (not done as required, according to 2011
Inspection Report).
The draft permit includes the same parameters as the EPA Multi -Sector Stormwater General Permit for the
Timber Products Sector (saw mills and wood preserving subcategories), except for zinc because there are
no significant sources based on the application information. The draft permit includes the additional
parameters of TPH, BOD, and pH.
8. Qualitative Monitoring Notes: Not submitted to Central Files under a general permit; not available. Not
performed, according to 2011 Inspection Report.
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NCS00552
Permit Recommendations:
Analytical Monitoring:
1. As with the General Permit for Timber Products (NCG210000), the draft proposes monitoring for Total
Suspended Solids (TSS), and Chemical Oxygen Demand (COD), which are pollutants associated with
wood saw mills. In addition, monitoring is proposed for Biochemical Oxygen Demand (BOD, 5-day)
ammonia, copper, chromium, and arsenic because of past and present wood preserving operations (CCA
until 2003/04, followed by a switch to ACQ solution). ACQ contains copper and a quaternary
ammonium compound. Ammonia nitrification will exert both a BOD and COD, although COD will
measure cellulose oxygen -consuming potential (in woody debris) that the BOD, 5-day test will not. In
combination, BOD and COD may help isolate a stormwater contaminant cause; however, data for this
permit term may reveal that one of these parameters is a better indicator (or adequate surrogate) for the
activities at this mill. The draft also includes "Non -Polar Oil & Grease," AKA Total Petroleum
Hydrocarbons (TPH) using the less inexpensive EPA Method 1664 SGT-HEM. Used/new oil and
petroleum -based cleaners are used and stored at the site, and there is oil in the equipment. The permit also
proposes pH monitoring, important for interpreting the toxicity of other parameters (standard for all
industrial NPDES stormwater permits with analytical monitoring).
2. Benchmarks for analytical monitoring are included in this draft permit. Benchmark exceedances require
the permittee to increase monitoring, increase management actions, increase record keeping, and/or install
stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tiered responses in the permit.
3. The benchmarks for TSS (30 mg/), COD (120 mg/1), BOD (30 mg/1), and pH (6-9 S.U.) are the same as
Secondary Treatment regulations for wastewater. These values reflect treated wastewater effluent quality
concentrations that should flag contamination problems in industrial stormwater discharges. The ammonia
benchmark (7.2 mg/1) is based on the 1/2 FAV (Final Acute Value) at a pH of 8, from EPA's 1999 Update
of Ambient Water Quality Criteria for Ammonia. Copper, chromium, and arsenic benchmarks (0.007 mg/l
— Tier 1, 1.0 mg/l, and 0.36 mg/1, respectively) reflect the current 1/2 FAVs for these metals, with a default
hardness of 50 mg/1. The TPH benchmark (15 mg/1) is consistent with other states (TX, NJ, WA) and
should only be exceeded when there is significant oil contamination.
4. When Triennial Review of the proposed new Water Quality Standards concludes, the SPU will revise
metals benchmarks with a new translation method for dissolved to total recoverable values, and the copper
benchmark will increase some (to 0.0105 mg/1). In the interim, the draft proposes a value twice the
current benchmark (0.014 mg/1)—close to the new value —serve as the trigger for Tiers 2 and 3 to grant
some relief to such a low copper benchmark. This site may have challenges meeting the benchmark
either way. Because the stream is impaired for copper and biological integrity, it will be important to
assess potential impacts from this facility's stormwater discharges.
5. There is the option to discontinue As monitoring after four consecutive samples are below the 0.36 mg/l
benchmark. The draft proposes this allowance because the facility stopped using CCA with arsenic as a
treatment chemical almost ten years ago.
6. The permittee is required to collect all of the analytical and qualitative monitoring samples during
measureable storm events as defined in Part II Section B. Qualitative monitoring is required regardless of
representative outfall status.
Other Proposed Conditions:
1. All standard for individual permits. If copper concentrations in the stormwater become an issue and are
impacting the receiving stream, DWQ may consider adding Mandatory BMPs or Special Conditions in a
future permit modification or renewal.
2. Does the Regional Office have any recommendations for Special Conditions for this site based on
information about current stormwater discharges?
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NCS000552
Discussions with permittee or represenative: Jeff Gerlock, Consultant (Blue Ridge Geological Services, Inc.),
336-382-6849 (mobile), 5/18/2012 and 6/15/2012.
1. Jeff Gerlock, Consultant (Blue Ridge Geological Services, Inc.), 336-382-6849 (mobile), 5/18/2012 and
6/15/2012. Returned call to update status of draft permit development.
Other correspondence:
From: Ratcliffe, Judith
Sent: Wednesday, June 20, 2012 11:09 AM
To: Georgoulias, Bethany
Subject: RE: Broad River, Rutherford County
Hi Bethany,
The NC Natural Heritage Program has no current records of state or federally -listed endangered, threatened, or
candidate species; or Critical Habitat within the referenced project area, nor within a one mile radius.
Judith Ratcliffe
Freshwater Ecologist, Eastern Region
NC Natural Heritage Program
919-707-8628
[e-mail]
www.ncnhp.org
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may
be disclosed to third parties.
From: Georgoulias, Bethany
Sent: Thursday, June 14, 2012 3:39 PM
To: Ratcliffe, Judith
Subject: RE: Broad River, Rutherford County
Hi Judy,
I understand you're our interim contact on threatened and endangered species, and I have a location to ask
about!
We are moving a wood treating facility under an individual stormwater permit (it's currently under a less stringent
general permit), and I wanted to check for T&E species in the vicinity. The facility (Anderson Land & Timber
Company) address is 127 Buck Seaford Road in Mocksville (Davie County), and the location coordinates are
(35.8687 deg. N and 80.5879 deg. W) I'm inquiring about any aquatic species in or near the receiving stream, Bear
Creek.
Thanks so much for your help!
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
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NCS000552
Recommendations: Based on the documents reviewed, the application information submitted on August 1,
2011 sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Original signed by Bethany Georgoulias Date 612012012
Stormwater Permitting Unit Supervisor _Original signed by Bethany Georgoulias _ Date 612012012
for Bradley Bennett
Concurrence by Regional Office Date
RO Water Quality Supervisor Date
Regional Office Staff Comments (attach additional pages as necessary)
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