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HomeMy WebLinkAboutNCS000291_Fact sheet binder_20230308DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer / Date Brianna Young 2/27/2023 Permit Number NCS000291 Owner / Facility Name McRae Woodtreating, Inc. / McRae Woodtreating Incorporated SIC AICS Code / Category 2491 / Wood Preserving Basin Name / Sub -basin number Yadkin Pee -Dee / 03-07-10 Receiving Stream / HUC UT to Big Branch / 030401040204 and 030401040404 (HUC runs through middle of site) Stream Classification / Stream Segment C / 13-16-5 Is the stream impaired on 303 d list]? No Any TMDLs? No Any threatened and/or endangered species? No Any compliance concerns? See Section 2 below Any permit mods since lastpermit? See Section 1 below New expiration date 3/31/2028 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: McRae Woodtreating, Inc. is a wood treating facility. The facility pressure treats southern yellow pine using two different preservatives: CA-C (copper azole type C) and Ecolife. Per the previous permit renewal fact sheet, the plant switched from CCA (chromated copper arsenate) to ACQ (alkaline copper quaternary) treatment in 2004 (tanks and cylinders were cleaned and CCA was shipped offsite). The drip pad is covered, curbed and bermed, and the water is directed to a pit and then to a holding tank, where it is recycled back into the treating plant. The 2010 permit application states only stormwater from roofs and ground water discharge off the site (no water from the drip pad runs offsite) and sample are collected from 3 to 4 different areas where water runs off the site. Per the 2018 renewal application, the facility has changed their chemical preservative from ACQ (ammonium copper quat) to CA-C (copper azole type C) and EL-2 preservative. Per the September 2022 inspection report, the facility is using a preservative called CA type C, which does not contain Chromium or Arsenic like the preservative previously used (ACQ). The current preservative contains Copper and Azole, which is a binding agent to keep the Copper in solution. Outfall SW001: Drainage area contains a covered loading and drip pad area, treatment building, office, and shop. Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. The term does not include discharges from facilities or activities excluded from the NPDES program under this part 122. For the categories of industries identified in this section, the term includes, but is not limited to, storm Page 1 of 6 water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or byproducts used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and intermediate and final products; and areas where industrial activity has taken place in the past and significant materials remain and are exposed to storm water. For the purposes of this paragraph, material handling activities include storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product, byproduct or waste product. The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm water [sic] drained from the above described areas." Section 2. Monitoring Information and Compliance History: • May 2011 to November 2022, benchmarks exceeded for: o TSS:4x o COD:4x o Copper: IOx • Per the September 2022 inspection report, several monitoring periods have been missed; monitoring only conducted and recorded for May 2011, May 2012, August 2012, February 2014, February 2015, December 2016, December 2018 and November 2021. o Results indicated benchmark exceedances for Copper o All other parameters below the respective benchmark values • NOV-2011-PC-0057 issued January 2011 for failure to develop/implement a SPPP and failure to perform analytical and qualitative monitoring • September 2022 inspection found several deficiencies: o NOV issued (see below) o During previous permit cycle, monitoring was only conducted May 2011, May 2012, August 2012, February 2014, February 2015, December 2016, December 2018, and November 2021 o Monitoring results indicate exceedances of the copper benchmark value NOV-2022-PC-0583 issued September 2022 for an inadequate SPPP and failure to conduct/record monitoring results DEMLR FRO staff recommendation 9/2022: Based on the change in preservative as well as the available monitoring records indicating results well below the benchmark values for Chromium and Arsenic, the removal of Chromium and Arsenic from the monitoring parameters in the renewed permit should be considered. Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for July 2011 to November 2021. Quantitative sampling included BOD, COD, TSS, arsenic, chromium, copper, ammonia, and pH. Page 2 of 6 Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases, dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the proposed monitoring for each outfall at the McRae Woodtreating, Inc. site. Outfall SWO01 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring pH BASIS: Pollutant indicator Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non -Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum -based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Quarterly monitoring Ammonia Nitrogen BASIS: Discharge potential indicator Quarterly monitoring Total Copper BASIS: Potential pollutant from drainage area Quarterly monitoring Total Hardness BASIS: Monitoring for hardness dependent metal present Stormwater Benchmarks and Tiered Response: Rather than limits, North Carolina NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark concentrations are intended as guidelines for the facility's development and implementation of the Stormwater Pollution Prevention Plan (SWPPP). Benchmark exceedances require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a tiered approach to specify actions the permittee must take in response to analytical results above Page 3 of 6 benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide flexibility to address issues that may arise with one or more parameters and/or outfalls. Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of DWR. NC DWR follows established federal procedures for calculating acute standards when developing the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral nature of rainfall events. The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or ash removal in specific drainage areas at this site. For parameters that do not have a stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data become available or if rising trends in concentrations suggest a persistent source. A summary of the benchmarks in the draft permit, and their basis, is below: Parameter Benchmark Basis Total Suspended 100 mg/L National Urban Runoff Program (NURP) Study, 1983 Solids TSS H 6 s.u. — 9 s.u. NC Water Quality Standard (Range) Non -Polar Oil & Review of other state's daily maximum benchmark Grease 15 mg/L concentration for this more targeted O&G; NC WQS that EPA Method 1664 does not allow oil sheen in waters SGT-HEM BOD 30 mg/L g BPJ; Based on Secondary Treatment Regulation (40 CFR 133.03 COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Ammonia Nitrogen 5.6 mg/L Based on the mussels-present/trout absent acute criteria table summer in the 2013 EPA criteria document Ammonia Nitrogen 15 mg/L Based on the mussels-present/trout absent acute criteria table winter in the 2013 EPA criteria document Copper Total 10 /L Acute Aquatic Criterion, '/2 FAV Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's pollution prevention approach to stormwater permitting. The Division's maintains that implementation of Best Management Practices (BMPs) and traditional stormwater management practices that control the source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional Pollutant Control Technology (BCT). The permit conditions are not numeric effluent limitations but are designed to be flexible requirements for implementing site -specific plans to minimize and control pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal Regulations (CFR) § 122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act Page 4 of 6 under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT. Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an alternative monitoring plan for approval by the Region: • Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances, exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier Three. The Regional Engineer may direct the response actions on the part of the permittee as provided in Tier Three, including reduced or additional sampling parameters or frequency. • If pursuing the alternative above after two consecutive exceedances, the permittee may propose an alternative monitoring plan for approval by the Regional Engineer. The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For example, the permittee may request that mercury only be monitored semi-annually under the tiers, or that only parameters over the benchmark be monitored more frequently. In this way, changes to the monitoring scheme for any outfall could be handled outside of a permit modification. Other Proposed Requirements: • It is standard for Stormwater Pollution Prevention Plan (SWPPP) requirements to include an annual certification that stormwater outfalls have been evaluated for the presence of non- stormwater discharges, and if any are identified, how those discharges are permitted or otherwise authorized. • Requirement to submit a request for permit modification if the facility identifies or creates any new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants. • The Division expects the permittee to apply best professional judgment and consider the safety of its personnel in fulfilling sampling obligations under the permit. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the EPA. • Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout year. Section 4. Chances from previous permit to draft: • Monitoring increased from semi-annually to quarterly for all parameters (qualitative and quantitative) • "No discharge" clarifications made • eDMR requirement added • Boilerplate language moved into body of the permit; boilerplate no longer attached • Facility address updated based on permittee comments • Monitoring for total hardness added as monitoring for hardness dependent metals is required • Monitoring for Estimated Average Monthly Oil Usage added to the permit as standard monitoring requirement for all SW permits • Benchmarks updated for parameters per guidance from DWR Standards group on stormwater benchmarks Page 5 of 6 Ammonia nitrogen split into summer and winter benchmarks Monitoring for arsenic and chromium removed for all outfalls as wood treatment chemical changed (per DEMLR FRO staff) o Monitoring data all below benchmarks Section 5. Changes from draft to final: • None Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility: 8/12/2022 • Initial contact with Regional Office: 8/12/2022 • Draft sent to CO peer review: N/A • Draft sent to Regional Office: 1/3/2023 • Final permit sent for supervisor signature: 2/27/2023 Section 7. Comments received on draft permit: Mike Lawyer (FRO; via email 1/10/2023): Subject draft permit looks good. Under the Tier Three response actions table it says "Monitor all parameters monthly (qualitative and quantitative) at appropriate outfall(s)." Does this mean that Tier Three now triggers monthly monitoring? I'm thinking of a scenario where a facility is not in Tier Two, but has had four benchmark exceedances during the permit term, which do not have to be consecutive exceedances. o DEMLR response: The Tier Response condition in the permit is the standard language used in all individual permits. Monthly monitoring is required if they hit Tier III, but this isn't a new requirement to my knowledge. Page 6 of 6 2 4 2023 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE NPDES STORMWATER DISCHARGE PERMITS The North Carolina Environmental Management Commission proposes to issue NPDES storrnwater discharge permit(s) to the person(s) listed below. Public comment or objection to the draft permits is invited. Written com- ments regarding the proposed permit will be accepted until 30 days after the publish date of this notice and considered in the final determination regarding permit issuance and permit provisions. The Director of the NC Division of Energy, Mineral, and Land Resources (DEMLR) may hold a public hearing should there be a significant degree of public interest. Please mail com- ments and/or information requests to DEMLR at 1612 Mail Service Center, Raleigh, NC 27699-1612. • McRae Woodtreating, Inc. [105 National Street, Mt. Gilead, NC) has requested renewal of permit NCS000291 for the McRae Woodtreating, Inc. facility in Montgomery County. This facility discharges to an unnamed tribu- tary to Big Branch in the Yadkin Pee -Dee River Basin. Interested persons may visit DEMLR at 512 N. Salisbury street, Raleigh, NC 27604 to review information on file. Additional information on NPDES permit; and this notice may be found on our website: https://deq.nc.gov/about/divi- stonnwater-public-notices, or by contacting Brianna Young at brianna. young@nodenr.gov or919-707-3647.3 Certificate of Publication Montgomery County, North Carolina: Tammy Dunn, Editor of the Montgomery Herald, a newspaper in Montgomery County, State of North Carolina, being duly sworn, deposes and says that the Advertisement or Notice in the action entitled. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE NPDES STORMWATER DISCHARGE PERMITS was Duly Published in the Montgomery Herald once a week for 1 week(s) beginning January 18, 2023 and ending January 18, 2023. Tammy Dunn, Publisher Publisher The Montgomery Herald Sworn to before me this the 19 day January, 2023. I Notary Public My c mmission expires 2D — 2� is JESSICA M. BURRIS Notary Public, North Carolina Montgomery County My Commission Expires September 20,2027 Young, Brianna A From: Rodney Mcrae <rjmcrae@embargmail.com> Sent: Thursday, December 8, 2022 10:34 AM To: Young, Brianna A Subject: [External] Follow up to request for information for McRae Woodtreating Stormwater Permit Attachments: Scan2022-12-08_103021.pdf, Stormwaterrecord.xlsx CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Good Morning, Thank you again for following up with us. With regard to the requested information: 1- We do only have 1 outfall location 2 - The Stream Index Number is 13-16-5 3 - The industrial activity that occurs on our property is that we pressure treat southern yellow pine using two different preservatives. The first preservative is CA-C (copper azole type C) currently purchased from the Viance Corporation. The second preservative we use is called Ecolife also purchased from the Viance corporation. The outfall area is at a drainage ditch near the trucking entrance to the property. I have also attached an updated a copy of our latest analytical report (results page), entire report available at your request. Similarly, I have attached a summary spreadsheet showing the latest report. Please let me know if you need any further information. Thank you, Rodney McRae McRae Woodtreating Inc. Young, Brianna A From: Rodney Mcrae <rjmcrae@embargmail.com> Sent: Thursday, December 8, 2022 2:31 PM To: Young, Brianna A Subject: [External] eDMR request Attachments: Scan2022-12-08_133836.pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Good Afternoon, Thank you for your help earlier. There is just a slight difference in the updated form and the forms that I had on file. I would also like to add regarding our activity that is being done in the drainage area that we are no longer treating with the old chemical known as CCA ( copper chrome and arsenic AKA copper chromate). We have not used that chemical since 2004. In addition, I am trying to bring us up to date regarding the eDMR. We had sent the registration form in December of 2000, but had heard there were problems with the registrations. I have attached the registration form that we completed from Dec. 2020 with the only change being our address. As mentioned in a earlier email, our facility has not moved but the address change reflects our correct 911 address. We have switched our contact information to this address after an incident where the authorities were responding to a break in and they went to the wrong location. Please let me know if you need any additional information regarding the eDMR. Thanks, Rodney McRae McRae Woodtreating Inc. NCS000291 s ' Waypoint. `•� 449 Springbrook Rd, Charlotte, NC 28217 Main 704.529.6364 ANALYTICAL www.waypointanalytical.com 00145 McRae Wood Treating. Inc. Project Stormwater Runoff Rodney McRae Report Date : 11/10/2022 455 Hwy 109 North2p. O. Box 8 Information : Received : 11/01/2022 P. O. Box 8 /� Mount Gilead , NC 27306 U LJ 1(- Terri W Cole Report Number : 22-305-0013 REPORT OFANALYSIS Laboratory Project Manager Lab No : 91926 Matrix: Aqueous Sample ID : Storm Water Sampled: 11/1/2022 9:25 Test Results Units MQL DF Date / Time By Analytical Analyzed Method Ammonia Nitrogen 0.16 mg/L 0.10 1 11/02/22 09:33 CLB 4500-NH3G-2011 Biochemical Oxygen Demand (5-day) 6.0 mg/L 2.0 1 11/02/22 12:14 SLO 521OB-2015 COD (Chemical Oxygen Demand) <50 mg/L 50 1 11/02/22 10:43 SMW 5220D-2011 pH 7.0 H s.u. 1 11/02/22 13:20 CLB 4500H+B-2011 Total Suspended Solids 25.7 mg/L 7.1 1 11/07/22 13:50 CMJ 2540D-2015 Arsenic 0.0250 mg/L 0.0010 1 11/04/2219:39 EDV 200.8 Chromium 0.001 mg/L 0.001 1 11/04/2219:39 EDV 200.8 Copper 0.0422 mg/L 0.0020 1 11/04/2219:39 EDV 200.8 Qualifiers/ DF Dilution Factor Definitions MQL Method Quantitation Limit H Beyond holding time Page 5 of 7 Date Contaminants Arsenic (µg/L) Chromium (µg/L) 11/1/2022 25 1 11/22/2021 6.28 4.22 11/12/2019 BRL BRL 12/28/2018 29 7.8 12/6/2016 76 54 2/2/2015 55 50 2/21/2014 10 7.6 8/20/2012 15 BRL 5/9/2012 66 59 5/17/2011 12 6.1 7/26/2011 Copper (µg/L) Ammonium (mg/L) 42.2 0.16 17.7 <0.10 30 BRL 38 0.1 360 0.15 200 BRL 28 BRL 38 BRL 120 0.26 20 0.23 BODS (mg/L) COD (mg/L) 6 <50 5.5 <50 9.4 51 BRL 71 4.8 60 BRL 130 BRL 130 6.6 160 N/A 140 N/A BRL 10 Total Suspended Solids (mg/L) pH 25.7 7 36.8 6.98 53 7.1 90 7 230 7.5 550 6.5 250 6.9 20 6.6 380 N/A 39 N/A 6 Young, Brianna A From: Lanna McRae <lannamcrae@embarqmail.com> Sent: Tuesday, November 1, 2022 5:20 PM To: Young, Brianna A Subject: [External] Fw: RE: Fw: RE: Stormwater permit McRae Woodtreating Inc. (NCS000291) Attachments: Stormwaterrecord.xlsx CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. On Tue, 1 Nov, 2022 at 5:16 PM, rodney@pdgolfcarts.com <rodney@pdgolfcarts.com> wrote: Good Afternoon, We have received your request for updated information regarding our permit. Upon review of the listed information we have verified that all of our information, industrial activity and operational procedures are the same with the exception of a 911 address. Our physical location has not changed but our 911 address system has us listed as 105 National St instead of the 455 Julius Chambers Ave. The Julius Chambers Avenue is the name of a short portion of NC Hwy 109 inside the city limits, and National Street is the name of our private drive located off of Julius Chambers Ave. Prior to your contacting us, we were inspected by Mike Lawyer. As a result of his inspection and recommendation, we have made several improvements to our documentation procedures. We have always strived to keep our risk of stormwater contamination to a minimum, and we have welcomed his feedback to make improvements. As mentioned earlier, we have made improvements to our documentation procedures and so you will find the attached spreadsheet with our sample records to be sparse. We have already implemented the changes to rectify this issue moving forward and have a stormwater sample awaiting analysis at the lab. Please let me know if I need to make this address change with Bethany Georgoulias as we have not moved but are only changing our address to reflect our correct 911 addressing system. Also, please let me know if you need any further information. Rodney McRae -----Original Message ----- From: "Lanna McRae" <Iannamcrae@embargmail.com> Sent: Tuesday, November 1, 2022 2:25pm To: rjmcrae@embargmail.com, rodney@pdgolfcarts.com Subject: Fw: RE: Stormwater permit McRae Woodtreating Inc. (NCS000291) On Wed, 19 Oct, 2022 at 10:42 AM, Young, Brianna A <Brianna.Young@ncdenr.gov> wrote: To: mcraewoodtreating@embargmail.com Cc: lannamcrae@embarqmail.com Good morning, Thank you for taking my call this morning. Below is the information I previously requested. This information is needed in order to proceed with reviewing the stormwater permit renewal application. Please let me know if you have any questions as you work through the request. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ / Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Young, Brianna A Sent: Wednesday, September 14, 2022 3:14 PM To: mcraewoodtreating@embargmail.com Subject: RE: Stormwater permit McRae Woodtreating Inc. (NCS000291) Good afternoon, I am following up on our previous correspondence. In order to continue with the permit renewal review, the requested information must be submitted. To date I have not received anything. Please submit this information as soon as possible. If you have any questions on this request, please let me know. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ / Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Younq@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Young, Brianna A Sent: Friday, August 12, 2022 10:15 AM To: mcraewoodtreating[a@embarq mail. com Subject: Stormwater permit McRae Woodtreating Inc. (NCS000291) Good morning, I am working on renewing the individual stormwater permit for McRae Woodtreating Inc. (NCS000291). I need additional information in order to 1) confirm that the information I have is correct and 2) make sure the permit adequately serves the needs of the facility. Please provide the following: • Confirmation on the number of outfalls and outfall coordinates; • SIC/NAICS code; • Description of industrial activity in each drainage area; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. Please review the facility information to make sure it is correct. Information can be updated using the links provided below, where applicable: Facility/Company name or ownership: Name/Ownership Change Form Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to represent the company per signatory requirements or another authorized representative): Permit Contact Update Request Form Delegation of Signature Authority (DOSA): Permit Contact Update Request Form Billing contact: Permit Contact Update Request Form Permit contact: Permit Contact Update Request Form Facility contact: Permit Contact Update Request Form Facility address only: Email Bethany Georgoulias Stormwater outfall information: Email Bethany Geor og ulias Visit the eDMR Six Steps website and complete Steps 1 and 2. Pay outstanding permit fees: Stormwater ePayment website Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day comment period. During this time we will be able to address any comments or concerns you have. During the same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public notice. Once all comments and concerns are addressed, you may be issued a final permit. Please contact me if you have any questions. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ / Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young(a�ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and trom this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. Date Contaminants Arsenic (µg/L) Chromium (µg/L) Copper (µg/L) Ammonium (mg/L) 11/22/2021 6.28 4.22 17.7 <0.10 11/12/2019 BRL BRL 30 BRL 12/28/2018 29 7.8 38 0.1 12/6/2016 76 54 360 0.15 2/2/2015 55 50 200 BRL 2/21/2014 10 7.6 28 BRL 8/20/2012 15 BRL 38 BRL 5/9/2012 66 59 120 0.26 5/17/2011 12 6.1 20 0.23 7/26/2011 BODS (mg/L) COD (mg/L) 5.5 <50 9.4 51 BRL 71 4.8 60 BRL 130 BRL 130 6.6 160 N/A 140 N/A BRL 10 Total Suspended Solids (mg/L) pH 36.8 6.98 53 7.1 90 7 230 7.5 550 6.5 250 6.9 20 6.6 380 N/A 39 N/A 6 Compliance Inspection Report Permit: NCS000291 Effective: 04/01/11 Expiration: 03/31/16 Owner: McRae Woodtreating Inc SOC: Effective: Expiration: Facility: McRae Woodtreating Inc County: Montgomery 455 Julius Chambers Ave Region: Fayetteville Mount Gilead NC 27306 Contact Person: Rodney McRae Title: Plant Manager Phone: 910-439-6281 Directions to Facility: System Classifications: SWNC, Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Inspection Date: 09/22/2022 Primary Inspector: Mike Lawyer Secondary Inspector(s): Certification: Phone: Rodney McRae 910-439-6281 Entry Time 10:05AM Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Exit Time: 12:35PM Phone: 910-433-3394 Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc Inspection Date: 09/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection conducted as part of the permit renewal process. Permit renewal application submitted in early 2018. Reviewed facility's current Stormwater Pollution Prevention Plan (SWPPP), which is dated March 2018. The SWPPP contains the major components, however there is no documentation pertaining to the annual review and update requirements for employee training, listing of significant spills or notation that none have occurred, non-stormwater certification, etc. Additionally, there is no documentation of a feasibility study or facility inspections. The site map needs more detail to show the location of the stormwater outfall(s), material storage areas, disposal areas, loading/unloading areas, site topography, drainage features, drainage areas for each outfall, direction of stormwater flow, etc. In reviewing the facility's available monitoring records, it appeared that several monitoring periods have been missed. The monitoring frequency under the current/expired permit is semi-annual, however monitoring was only conducted and recorded during the following periods; May 2011, May 2012, August 2012, February 2014, February 2015, December 2016, December 2018 and November 2021. The monitoring results indicate exceedances of the benchmark value for Copper with all other parameters below the respective benchmark values. Vehicle maintenance is conducted onsite, but less than 55 gallons of new motor oil is used per month. After the SWPPP/records review, observations were made of site conditions including the covered loading area and drip pad, sheltered product storage area, ASTs with secondary containment, and stormwater outfall. Based on the information provided in the permit renewal application and onsite discussion with Mr. Rodney McRae, facility is currently using a preservative called CA type C, which does not contain Chromium or Arsenic like the preservative previously used (ACQ). The current preservative contains Copper and Azole, which is a binding agent to keep the Copper in solution. Based on this change in preservative as well as the available monitoring records indicating results well below the benchmark values for Chromium and Arsenic, the removal of Chromium and Arsenic from the monitoring parameters in the renewed permit should be considered. Page 2 of 3 Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc Inspection Date: 09/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ❑ ❑ # Does the Plan include a BMP summary? ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ 0 ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑ Comment: Site map does not contain the necessary details as required by the permit. A feasibility study is not incorporated into the SWPPP. There is no documentation of an annual review/update to include employee training, spill history, non-stormwater certification, etc. Qualitative Monitoring / ]r- ]..�.1N Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑ Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection Summary for details. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑ Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection Summary for details. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ # Were all outfalls observed during the inspection? ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 ❑ ❑ Comment: Page 3 of 3 ROY COOPER Governor ELIZABETH S. BISER Secretory BRIAN WRENN Director CERTIFIED MAIL: 7018 0040 0000 4771 9619 RETURN RECEIPT REQUESTED McRae Woodtreating, Inc. Attn: Stimpson McRae, President PO Box 8 Mount Gilead, NC 27306 NORTH CAROLINA Environmental Quality September 28, 2022 Subject: NOTICE OF VIOLATION (NOV-2022-PC-0583) NPDES Individual Stormwater Permit NCS000291 McRae Woodtreating, Inc. Montgomery County Dear Mr. McRae: On September 22, 2022, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the McRae Woodtreating, Inc. facility located at 455 Julius Chambers Avenue (105 National Street) in Montgomery County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Rodney McRae, Plant Manager, and Mrs. Lanna McRae, Office Manager, were also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Individual Stormwater Permit NCS000291. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an unnamed tributary to Big Branch, a class C stream in the Yadkin -Pee Dee River Basin. As a result of the site inspection, the following permit conditions violations are noted: 1) Stormwater Pollution Prevention Plan (SPPP) Per Part II, Section A, item 1(c)... The site map included with the Stormwater Pollution Prevention Plan does not show all of the required information as detailed in the permit. Per Part II, Section A, item 1(e)... There is no documentation that the stormwater outfalls have been evaluated or re -certified annually for the presence of non-stormwater discharges. Per Part II, Section A, item 2(a)... There is no documentation of a feasibility study. Per Part 11, Section A, item 5...There is no documentation of annual employee training. Per Part II, Section A, item 7...There is no documentation of an annual review/update, which would include an updated list of significant spills or notation that none have occurred, re -certification that the stormwater outfalls have been evaluated for the presence of non-stormwater discharges, and re-evaluation of the effectiveness of the BMPs. Per Part II, Section A, item 8... There is no documentation regarding facility inspections, which are different from and in addition to the stormwater discharge monitoring requirements. Per Part II, Section A, item 9... Based on the lack of documentation as detailed above, the Stormwater Pollution Prevention Plan has not been properly implemented. North Carolina Department of Environmental Quality (Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street. Suite 714 ( Fayetteville, North. Carolina 28301 :verirr; cva„unu '�"" Upml-dal Em(runmenUl Que11tY 910.433.3300 2) Analytical Monitoring Requirements Per Part 11, Section B... Analytical monitoring has not been conducted and/or recorded in accordance with permit conditions. 3) Qualitative Monitoring Requirements Per Part 11, Section C... Qualitative monitoring has not been conducted and/or recorded in accordance with permit conditions. Other Observations Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Requested Response You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written response should include a reasonable explanation as to why the aforementioned violations have occurred as well as a Plan of Action to prevent these violations from recurring. Action Items Immediately review and amend the facility's Stormwater Pollution Prevention Plan as needed and begin incorporating documentation pertaining to the annual update requirements of the permit. Conduct and record monitoring per the conditions of the permit. Thank you for your attention to this matter. This office requires that the violations, as detailed above and summarized in the enclosed inspection report, be properly resolved. These violations and any future violations are subject to a civil penalty assessment of up to $25,000 per day for each violation. Should you have any questions regarding these matters, please contact Mike Lawyer at (910) 433-3394 or mike.lawyer@ncdenr.gov. Sincerely, imothy L. LaB y, PE Regional Engineer DEMLR TL/ml Enclosure: Compliance Inspection Report ec: Rodney McRae, Plant Manager — McRae Woodtreating, Inc. Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR Brad Cole, PE, Chief of Regional Operations — DEMLR Danny Smith, Supervisor— DEMLR, Stormwater Program Brianna Young, Industrial Individual Permits Coordinator — DEMLR, Stormwater Program DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO — DEMLR, Stormwater Files Compliance Inspection Report Permit: NCS000291 Effective: 04/01/11 Expiration: 03/31/16 Owner: McRae Woodtreating Inc SOC: Effective: Expiration: Facility: McRae Woodtreating Inc County: Montgomery 455 Julius Chambers Ave Region: Fayetteville Mount Gilead NC 27306 Contact Person: Rodney McRae Title: Plant Manager Phone: 910-439-6281 Directions to Facility: System Classifications: SWNC, Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Certification: Phone: Rodney McRae 910-439-6281 Inspection Date: 09/22/2022 Entry Time 10: 5AM Primary Inspector: Mike Lawyer Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ❑ Compliant Not Compliant Question Areas: N Storm Water (See attachment summary) Exit Time: 12:35PM Phone: 910-433-3394 Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc Inspection Date: 09/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection conducted as part of the permit renewal process. Permit renewal application submitted in early 2018. Reviewed facility's current Stormwater Pollution Prevention Plan (SWPPP), which is dated March 2018. The SWPPP contains the major components, however there is no documentation pertaining to the annual review and update requirements for employee training, listing of significant spills or notation that none have occurred, non-stormwater certification, etc. Additionally, there is no documentation of a feasibility study or facility inspections. The site map needs more detail to show the location of the stormwater outfall(s), material storage areas, disposal areas, loading/unloading areas, site topography, drainage features, drainage areas for each outfall, direction of stormwater flow, etc. In reviewing the facility's available monitoring records, it appeared that several monitoring periods have been missed. The monitoring frequency under the current/expired permit is semi-annual, however monitoring was only conducted and recorded during the following periods; May 2011, May 2012, August 2012, February 2014, February 2015, December 2016, December 2018 and November 2021. The monitoring results indicate exceedances of the benchmark value for Copper with all other parameters below the respective benchmark values. Vehicle maintenance is conducted onsite, but less than 55 gallons of new motor oil is used per month. After the SWPPP/records review, observations were made of site conditions including the covered loading area and drip pad, sheltered product storage area, ASTs with secondary containment, and stormwater outfall. Based on the information provided in the permit renewal application and onsite discussion with Mr. Rodney McRae, facility is currently using a preservative called CA type C, which does not contain Chromium or Arsenic like the preservative previously used (ACQ). The current preservative contains Copper and Azole, which is a binding agent to keep the Copper in solution. Based on this change in preservative as well as the available monitoring records indicating results well below the benchmark values for Chromium and Arsenic, the removal of Chromium and Arsenic from the monitoring parameters in the renewed permit should be considered. Page 2 of 3 Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc Inspection Date: 09/22/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? 0 ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ M ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ 0 ❑ ❑ # Does the facility provide all necessary secondary containment? M ❑ ❑ ❑ # Does the Plan include a BMP summary? M ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? M ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ 0 ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ M ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑ Comment: Site map does not contain the necessary details as required by the permit. A feasibility study is not incorporated into the SWPPP. There is no documentation of an annual review/update to include employee training, spill history, non-stormwater certification, etc. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑ Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection Summary for details. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑ Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection Summary for details. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑❑■❑ ❑■❑❑ Page 3 of 3 8/12/22, 10:14 AM North Carolina Secretary of State Search Results • File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online - Add Entity to My Email Notification List • View Filings • Print a Pre -Populated Annual Report form • Print an Amended a Annual Report form Business Corporation Legal Name McRae Woodtreating, Inc. Information Sosld: 0093001 Status: Current -Active O Date Formed: 10/17/1984 Citizenship: Domestic Fiscal Month: December Annual Report Due Date: April 15th Currentgnnual Report Status: Registered Agent: McRae, James Stimpson Addresses Principal Office 455 N. Wadesboro Blvd. Mount Gilead, NC 27306 Mailing PO Box 8 Mount Gilead, NC 27306 Officers Reg Office 455 N. Wadesboro Blvd. Mount Gilead, NC 27306 Vice President/Secretary Doris T McRae PO Box 8 Mount Gilead NC 27306-0008 Reg Mailing PO Box 8 Mount Gilead, NC 27306 President/Treasurer James Stimpson McRae PO Box 8 Mount Gilead NC 27306 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1 /2 8/12/22, 10:14 AM Stock North Carolina Secretary of State Search Results Class: COMMON Shares: 100000 Par Value 1 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2 NC Division of Energy, inerai and Land Resources 7I 1 NPDES Stormwater Permit Contacts Summary NC DENILlt has the follow im,, contact information in our Permit Database for vour permit as of 2115/2018. M1�' Permit Number: NC5000291 Permit Type: Stormwater Discharge. Individual Name: McRae Woodtreating Incorporated EFacility f EFI Facility Addressl: AaJulius Chambers Ave U MAR Q Facility Addressl: 8 2016 City, State & Zip: Mount Gilead, NC 27306 f�p�y"�'y •�;�%J sJ�L1 �7 Owner Information Details: MUST submit a Change ofName/Ownershipform to DEMLR to make any changes to this Owner information. See "Miscellaneous Forms" at litti)://oortal.ncdenr.org/weblir/nt)des-stormwater Owner Name: McRae Woodtreating Inc Owner Type: Non -Government Owner Type Group: Organization *** Legally Responsible for Permit *** (Responsible corporate ofFicerlprinciple executive officer or ranking elected official/ genera I partner or proprietor; or any other person with delegated signatory authority from the legally responsible person.) owner Affiliation: Stimpson McRae Title: Addressl: PO Box 8 Addressl: City, State & Zip: Mount Gilead, NC 27306 Work Phone: 910-439-6281 Fax: Email Address: *** Permit Annual Fee Billing *** Billing Month: December Invoice Number Invoice Date Invoice Due Date Invoice Amount Invoice Status Owner Contact Person(s) Contact Name Title Address Phone Fax Email Facility Contact Person(s) Contact Name Title Address Phone Fax Email Permit Contact Persons) Contact Name Title Address Phone Fax Email Permit Billing Contact Contact Name Title Address Phone Fax Email Stimpson McRae PO Box 8, Mount Gilead, NC 27306 910-439-6261 2/15/2018 or, :r• 1 Renewal Permit Coverage al Application Form National Pollutant Discharge Elimination System NP NC Permit Number NCDENR Stormwater Individual Permit S pop 2 91 Please provide your permit number in box in the upper right hand corner, complete the information in the space provided below and return the completed renewal form along with the required supplemental information to the address indicated. Owner Information Owner / Organization Name: Owner Contact: Mailing Address: �kA Phone Number: ' Fax Number: E-mail address: Facility Information Facility Name: Facility Physical Address: Facility Contact: f4X Mailing Address: - • ti C Kc/,,— 1 V Jf Orq''c� v.i! ,s ho.—b-z ✓-e- Phone Number: ;;L V 1 Fax Number: 0 2� E-mail address: o�oJ t ra-z 'i e Permit Information S� Permit Contact: • M 1on y1�1�- Mailing Address: Phone Number: Fax Number: E-mail address: Discharge Information (� Receiving Stream: Stream Class: Basin: k .. cc - ► ivc� Asp .. Sub -Basin: Number of Outfalls: Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a separate hheet if necessary. ! � � � 1 L �� ci 1 C7 �i� � Lr.,s � ►✓1 . � 1 S.T Kra n [-� 0 �� { ' � � � Ccs-'r-ryFw� �aS Cyr CL I s:I�tirrlo.1-` .TC + C w 4 �sy- C,r� c, rd�•-4 C�►i. EGu l!#C i4ne� - fades 6�S 0. 2ta�C '^ i�S�r+%��L CERTIFICATION P�Ju S.s�s 1-�✓t �wta r.� A---q- S­ 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 t , complete and accurate. Signature �'`� ` Date Print or type name of person signing above Title SW Individual Permit Coverage Renewal Please return this completed application form Stormwater Permitting Program and requested supplemental information to: 1612 Mail Service Center Raleigh, North Carolina 27699-1612 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: (Do not submit the site Stormwater Pollution Prevention Plan) Initials 1*. 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 terns 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. 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, n parameters surveyed, observations, and date monitoring conducted. 4. 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. 5. 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. 6. 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) STORMWATER POLLUTION PREVENTION PLAN DEVELOP , :`NT ANDI MP , LE, � NTATION CERTIFICATION North Carolina Division of Energy, Mineral and Land Resources - Storm water Partnitting Facility Name: Permit Number: Location Address: County: d 2ll lk&M c.?i- N "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 properly 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." qnd "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." qnd "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 10, Date �Tj ✓Y1 422S" ' Print or typ6 name of person signing above Title SPPP Certification 10/13 Pictures of Material Handling, Storage and Secondary Containment r= JON C: LOCATION MAP NCS000291 �U / AW Scale 1:24, 000 Map A-1 McRae Woodtreating, Inc. Lautude: 35° 13' 22"N Longitude: 80° 0' 14" W Qxnly: Mxltgonery ReceHng Stream: UT to Bg branch Stream Qws; C SLt basin: 13-16-5 (Yadan River BBsn) Pan I Page 2 of Permit No. NC5000291 "-T Facility Location Map A-2 0 e I ry W19 / / 6) )0,,1 -r ccr., -, e- 0 4 1SX-49y G -SCADO I & P,4 I- I- ST PINE CIR ar 8c ALLENTON E. ------- (D rN Sl W. STA14MCK ST na `}'i7'1 4'.. •F-G-! t �,�_ rfli r as 1 r ]rJ { L''I -�� iF +� k rr r Q♦ l i i_*4Z� r�s ►. SyK r l ,,fr �'�;t� � ,y'.�:t� *. #3 • e 8 c �A f+. �� A Li { E'" 'Fly, [� C-!'Fly , fi=•?f a '.ry .� ' t k•Fr .•1c :� ,r i'.I r 1 r •J w' •,� � : pl 45S JI IIr Au M1wd•> d tdR_2.30l, r ,; ')•t +,, ��., �" :i 'dea f 3 /. _,l,' ie, � � r �� ,��I } � 5 ttY,'s'�Ft � � _•-� � 9r� .i I, r :C.-C:A � '�'.• c. .: G 10 o.. �i_... c rz �t ac taA .nn nS-.a .u��..l:��=a]: Ir1"., '�. 5[renmbnn. li'll I..:. '00'•� - .r .I .�`7'I Map B-1 Permit No. NCS000291 BANGLE UNITED STATES )EPARTMENT OF THE INTERIOR 7q�572 30f I JGRAPHICI GEOLOGICAL SURVEY C' 000 FEET • twOr 87 +,1. 3S '�J.' Bt�00 '9i�f ..aocrn�c s,a: 53 1 '94 57'30" '95 _ \� am 47 �t�' •' �' GAME LA av� .Nq - • 415 I �K , �• �� � .�� is •t,.` ! is _ _ -'� ��p .= —• :=, i - .. • r1,�1 i.�; , �,• • � a 731 . _ lam- 1•fl �'� I j . 0 - � ° : - _ , \ � 3' ✓ v '�• � .' 1 •'M�n le 0' �_�. i + , do •\ :�- VIS L. n L� �-� - 1- • ,•�' ' • _ t Page 3 Map B-2 N9 i m CL m OE: J m4 PAor w041- )-e,,�,,�� Summary of Analytical Monitoring Included below is a table showing the averages of the sampled data, storm event and location. Per the instructions, I have not included individual data. First recorded sampling was in May of 2011, and last recorded sampling during permit period was December 2016. Specific Item Average Outfall Area 1 Event rainfall at time of sampling 0.61 inches BOD 4.28 mg/L COD 96 mg/L Total Suspended Solids 218 mg/L Arsenic .0316 mg/L Chromium 0.0235 mg/L Copper 0.129 mg/L Ammonia .076 mg/L pH 6.7 Summary of Visual Monitoring Included below is a table summarizing the visual monitoring results, where an average number was not possible I have included the most consistent observation. Per the instructions, I have not included individual data. First recorded sampling was in May of 2011, and last recorded sampling during permit period was December 2016. Parameters Average or Most Consistent Observation Outfall Area 1 Color Overall transparent muddy/tint Odor None Clarity (1-5) 3 Floating Solids (1-5) 1 Suspended Solids (1-5) 2.2 Foam No Oil Sheen No Erosion No Summary of Best Management Practices From the beginning of the design of our facility, everything was designed to minimize the impact on storm water runoff with regards to the pressure treating process. All of our untreated lumber (southern yellow pine) comes into the treatment area from the left side (when facing the cylinder door), and this material is then removed to the drip pad from the right side after treatment. This entire process happens on a sloped pad which is designed to catch any chemical that may drip off, and then that chemical is recaptured and reused. After the lumber is treated it remains on the sloped drip pad until there are no visible signs of dripping. Furthermore, after all visible signs of dripping have ceased a substantial portion of our treated lumber is then stored under shed which prevents rain from running off the processed packs. All of our treating chemicals are stored in tanks and areas such that any spills could be contained in the event of malfunction, rupture or equipment failure into secondary containment. In addition to the design of the plant, we also make every effort to maintain our equipment by scheduled preventative maintenance to prevent leaks from machinery contaminating the ground. And, we notify any third parties that come to our property to transport lumber of any visible leaks that we see. Changes to Our Facility Since Last Permit Issuance Our overall treating process and safe handling practices have not significantly changed since our last permit issuance. However, our chemical preservative has changed. At the time of our last permit issuance, we were using ACQ (ammonium copper quat) under the trade name Preserve, and we are now using CA-C (copper azole type C) which is also under the trade name Preserve. In addition, we are also using EL-2 preservative, which is manufactured under the trade name Ecolife. The safe handling and storage practices remain the same as before. At the time of this writing, we have reviewed our storm water prevention plan, and made changes to reflect the different preservative. Furthermore, it is our desire to be in complete compliance, and we recognize even plans with the best of intentions can be tweaked or have room for improvement. It is with this desire that we have reviewed our plan to make any necessary tweaks going forward.