NCS000566_Renewal Application_20230324

ES2
Environmental Solutions and Strategies, LLC
P. 0. Box 4244
Martinsville Virginia 24115
March 20, 2023
Certified Mail— Return Receipt Requested RECEIVED
70210350 0000 9720 1667
Ms. Brianna Young
24 2023
Industrial Individual Permits Coordinator
DEMLR Storm Water Permitting Program rBa
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
RE: Fortress Wood Products, Storm Water Permit Renewal Application, NCS 000566
Dear Ms. Young,
Per your a-mails to Pete Haskins and our recent telephone conversations, please find
enclosed the completed Storm Water Permit Renewal Application, and one additional copy
thereof, for source NCS 000566, Fortress Wood Products, located at 3874 Bethel Drive Extension,
High Point, North Carolina, 27260
Thank you for your patience in this matter as we are still trying to determine why my name
and contact information was left off the original e-mail notifications to Fortress Wood Products.
Also thank you for taking the time in providing directions to correct this issue and for your helpful
guidance in getting this renewal application prepared.
Should you have any questions, concerns, or comments, with the aforementioned or the
permit renewal application(s) submitted herein, please contact me by telephone at (276) 806-
0178, by e-mail at [e-mail], or by facsimile at [phone].
Again, thank you so much for your help and assistance in getting these matters moving.
Sincerel
a ' x
President & CEO
Environmental Solutions and Strategies, LLC
P. O. Box 4244
Martinsville,Virginia 24115
276-806-0178 (telephone)
276-632-6137 (fax)
C: ES' Files
Fortress Wood Products—High Point Stormwater Files

FORTRESS WOOD PRODUCTS
3874 BETHEL DRIVE EXTENSION
HIGH POINT, NORTH CAROLINA 27260
STORM WATER PERMIT
NCS 000566 RECEIVED
WAR 2 4 2323
DEMLR-Stormwater Program
STORM WATER PERMIT APPLICATION
North Carolina Division of Energy,
Mineral, and Land Resources -
Stormwater Program
MARCH 17, 2023

TABLE OF CONTENTS
Supplemental Information Required for Renewal of 1
Individual NPDES Stormwater Permit
---------------------------------------------------------------------------------------------
Site Map From the Stormwater Pollution Plan with 2
Stormwater Outfalls Identified
-----------------------------------------------------------------------------------------------
Description of Industrial Activity Occurring Onsite and SIC 3
-----------------------------------------------------------------------------------------------
Summary of Analytical Monitoring Results During the Term 4
Of the Existing Permit
-----------------------------------------------------------------------------------------------
''�' Summary of the Visual Monitoring Results During the Term S
Of the Existing Permit
-----------------------------------------------------------------------------------------------
Summary of the Best Management Practices Utilized at 6
Permitted Facility
-----------------------------------------------------------------------------------------------
Short Narrative Describing any Significant Changes in 7
Industrial Activity at the Permitted Facility
-----------------------------------------------------------------------------------------------
Certification of the Development and Implementation of a 8
Stormwater Pollution Prevention Plan for the Permitted Facility
-----------------------------------------------------------------------------------------------

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
I. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities(including storage of materials, disposal areas,process areas and
loading and unloading areas), drainage structures,drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled,and storm event data.
&46h 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports.The summary can consist of a table including such items as outfall number,
parameters surveyed, observations,and date monitoring conducted.
_[�-vb 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)

Exhibit A2
Supplemental Information
tjW�"', , EPA Form 1 Section XI -Aerial map with Property Lines
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Fortress Wood Products
3874 Bethel Drive Extension
High Point, North Carolina 27260
Description of Industrial Activity Occurring Onsite
The major activity at the plant is the treatment of lumber products. Untreated lumber is received
from vendors on trucks or rail whereby it is unloaded, stored,and introduced into the treatment
process where each piece of wood is chemically treated to be resistant to.rot and decay. Lumber
remains on the treatment area drip-pad until the dripping of free liquid from the treatment
process is considered to have stopped. Once dripping has been determined stopped,the treated
lumber is removed to the storage yard,warehouses,or shipping area The process system
reclaims and recycles as much of the dripping as possible of treatment chemicals from the pads.
Currently,all chemicals used in the treatment process are stored inside the treatment process area
in totes and above ground storage tanks. The entire treatment area is covered by roof and is built
in such a manner whereby the treatment area would contain any catastrophic accident which
could cause the release of all the chemicals being stored.
The constant movement and storage of unprocessed and processed lumber does,during very dry
periods of time,causes the formation of fine dust on the surface of areas traversed on unpaved
areas. The formation of fine dust is kept to a minimum by rotating storage strategies.
The potential pollutants which could be expected to be present in the storm water discharge at
each outfall would be TSS from the dust accumulated on the yard,traces of
treatment chemicals,COPPER and their natural reactive chemistry,resultant a storm event
washing over the surface of treated wood that has been staged on the yard awaiting shipment to
customers,and COD and BOD from the interaction of oxygen with suspended solids and
treatment chemicals
An above ground double walled storage tank containing fuel for on-site vehicle operation resides
on a concrete pad that is covered and diked in order to contain a sufficient quantity of the
contents of the tank in the event of a spill.
The handling of waste by the facility is dependent upon the characterization of the waste.
Normally,the majority of waste generated at the facility is considered to be non-hazardous and
is therefore placed into appropriate dumpsters strategically located throughout the facility.These
wastes are removed from the facility on an as need basis and delivered to local landfills by
contracted waste carriers.
Hazardous waste materials are placed into hazardous waste satellite containers whereby they are
accumulated for subsequent transfer into hazardous waste drums which are dated, labeled as to
contents,and placed into secure storage awaiting removal from the premises by a licensed
hazardous waste carrier.
Due to vehicle maintenance being contracted off-site,there is little waste oil,lubricants,or
maintenance fluids with respect to vehicle maintenance.
Universal wastes are treated according to regulation and frequency of occurrence.

Fortress Wood Products
3874 Bethel Drive Extension
High Point, North Carolina 27260
SIC (NAICS) Code
SIC - 2491 '

FORTRESS WOOD PRODUCTS
STORMWATER PERMIT NUMBER -NCS 000566
ANALYTICAL SUMMARIES
Total Copper Total Nitrate- Ammonia
TSS COD Chloride Nitrite
Rainfall Recoverable Nitrogen pH
Inches mg/I mg/I m /I mg/I Nitrogen m /I
g
Sampling Date Sample Parameter Sampling Period mg/I g
Benchmarks >0.1 100 120 0.007 860 10 5.6 6.9
OUTFALL#1
6/5/2013 Semi-Annual Year 1-Period 1 0.10 76.0 146.0 1.410 8.30 0.985 1.290 6.09
12/10/2013 Semi-Annual Year 1-Period 2 0.25 94.0 56.0 0.874 7.50 0.212 0.147 5.80
January 2014 Tier II No Flow
February 2014 Tier II No Flow
March 2014 Tier II No Flow
4/7/2014 Semi-Annual Year 2-Period 1 0.50 66.0 65.0 0.408 <1.0 0.239 0.320 6.03
May 2014 Tier II No Flow
June 2014 Tier II No Flow
July 2014 Tier II No Flow
8/1/2014 Semi-Annual Year 2-Period 2 1.30 70.0 66.0 0.602 2.80 0.293 0.170 6.05
August 2014 Tier II No Flow
10/15/2014 Tier II 0.25 38.4 66.0 0.589 2.85 0.208 <0.010 5.41
11/14/2014 Tier II 0.25 66.2 73.0 0.640 <1.0 0.264 0.120 6.81
12/29/2014 Tier II 0.30 24.0 49.0 0.533 3.32 0.213 <0.100 6.31
1/23/2015 Tier II 0.40 31.0 48.0 0.419 2.38 0.223 0.140 N
February 2015 Tier II No Flow
3/27/2015 Tier II 0.30 20.0 24.0 0.316 1.42 0.776 0.100 N
April 2015 Tier II No Flow
May 2015 Tier II No Flow
June 2015 Tier II No Flow
July 2015 Tier II No Flow
August 2015 Tier II No Flow
9-25-2015 Semi-Annual Year 3-Period 1 0.60 33.0 71.0 0.601 12.00 <1.000 <0.100 5.99
10/27/2015 Tier II 0.25 49.5 106.0 1.080 1.40 0.572 0.127 5.74
11/02/2015 Tier II 1.52 23.0 64.0 0.852 0.94 0.138 <0.100 5.95
12/17/2015 Semi-Annual Year 3-Period 2 1.23 38.0 70.0 0.798 1.40 0.200 <0.100 6.11
January 2016 Tier II No Flow
2/16/2016 Semi-Annual Year 4-Period 1 1.07 26.0 44.0 0.445 2.81 1.030 0.190 6.03
March 2016 Tier 11 No Flow

}
FORTRESS WOOD PRODUCTS
STORMWATER PERMIT NUMBER -NCS 000566
ANALYTICAL SUMMARIES
Total Copper Total Nitrate-
Rainfall TSS COD Recoverable Chloride Nitrite Ammonia
Reco Nitrogen pH
/1 mg/I Nitrogen mg/I
Sampling Date Sample Parameter Sampling Period Inches mg/I mg/I mg mg/I
Benchmarks >0.1 100 120 0,007 860 10 5.6 6-9
OUTFALL#1
4/12/2016 Tier II 0.12 50.8 99.0 0.848 <1.000 0.350 <0.10 5.67
5/5/2016 Tier II 1.44 29.3 74.0 0.597 <1.000 <0.050 <0.10 5.15
April 2016 Tier II No Flow
May 2016 Tier II No Flow
June 2016 Tier 11 No Flow
July 2016 Tier II No Flow
August 2016 Tier II No Flow
9/22/16 Semi-Annual Year 4-Period 2 0.21 66.2 87.0 0.98 1.96 0.236 <0.10 5.34
October 2016 Tier II No Flow
November 2016 Tier II No Flow
December 2016 Tier II No Flow
01/23/2017 Semi-Annual Year 5-Period 1 0.89 20.0 40.0 0.885 1.88 0.128 <0.10 6.87
February 2017 Tier II No Flow
March 14,2017 Tier II >.100 0.168 7.18
April 24, 2017 Tier II >.100 0.127 6.40
May 23,2017 Tier II >.100 0.124
June 2017 Tier II 6.45
July 2017 Tier II
August 2017 Tier II
09/6/2017 Semi-Annual Year 5-Period 2 0.84 18.7 38.0 0.984 1.00 0.063 <0.10 6.32
October 2017 Tier II No Flow
November 2017 Tier II No Flow
December 2017 Tier 11 No Flow
January 2018 Tier II No Flow
February 2018 Tier II No Flow
March 2018 Tier II No Flow
April 2018 Tier II No Flow
May 2018 Tier II No Flow
6/2/2038 Semi-Annual Year 6-Period 1 1 .90 1 19.0 47.0 0.618 2.44 0.436 <0.10 7.40

1 I �
FORTRESS WOOD PRODUCTS
STORMWATER PERMIT NUMBER -NCS 000566
ANALYTICAL SUMMARIES
Total Copper Total Nitrate- Ammonia
Rainfall TSS COD Recoverable Chloride Nitrite Nitrogen pH
Inches mg/I mg/I mg/1 mg/I Nitrogen mg/I
Sampling Date Sample Parameter Sampling Period mg/I
Benchmarks >0.1 100 120 0.007 860 10 5.6 6-9
OUTFALL#1
February 2021 Tier II No Flow
March 2021 Tier II No Flow
April 2021 Tier II No Flow
May 2021 Tier II No Flow
June 2021 Tier II No Flow
07/08/2021 Semi-Annual Year 9-Period 2 0.6 20.3 133.0 2.690 1.20 0.580 NO 6.60
August 2021 Tier II No Flow
September 2021 Tier II No Flow
October 2021 Tier II No Flow
November 2021 Tier II No Flow
December 2021 Tier II No Flow
January 2022 Tier II No Flow
February 2022 Tier II No Flow
March 2022 Tier II No Flow
April 2022 Tier II No Flow
May 2022 Tier II No Flow
June 2022 Semi-Annual Year 10-Period 1 No Flow No measurable rainfall during work hours January 2022 through June 2022
July 2022 Tier II No Flow
August 2022 Tier II No Flow
September 2022 Tier II No Flow
October 2022 Tier II No Flow
November 2022 Semi-Annual Year 10-Period 2 1.2 29.6 163.0 6.630 3.00 0.530 ND 6.60
January 2023 Tier 11 No Flow
February 2023 Tier 11 No Flow

FORTRESS WOOD PROUCTS
STORMWATER PERMIT NUMBER - NCS 000566
STORMWATER DISCHARGE OUTFALL (SDO) QUALITATIVE MONITORING REPORTS
Floating Suspended
Solids Solids
Clarity 1 1 Other
1 no solids no solids Erosion or Obvious
Total Event very clear 5 5 Foam Oil Sheen Deposition Indications of
Precipitation Discharge Discharge 5. surface extremely Observed Observed Observed Yes Pollution
Sampling Date Sampling Period (Inches) Discharge Color Tint Odor very cloudy covered muddy Yes or No Yes or No or No Observed
Outfall#1
6/5/2013 Year 1-Period 1 0.10 Brown Light None 3 3 3 No No No None
12/10/2013 Year 1-Period 2 0.25 Gray Light None 2 1 1 No No No None
4/7/2014 Year 2-Period 1 1.64 Blue/Gray Light None 2 1 1 No No No None
8/1/2014 Year 2-Period 2 1.30 Greay Light None 3 2 2 No No No None
9/25/2015 Year 3-Period l 0.60 Gray/Brown Light None 3 2 2 No No No None
12/17/2015 Year 3-Period 2 1.23 Blue/Gray Light None 2 1 2 No No No None
2/16/2016 Year 4-Period 1 1.07 Gray Light None 3 1 1 2 1 No No No None
9/22/2016 Year 4-Period 2 0.21 Gray/Brown Medium None 4 2 2 No No No None
1/23/2017 Year 5-Period 1 0.89 Gray/Brown Light None 2 2 2 No No No None
9/6/2017 Year 5-Period 2 0.84 Gray Light None 2 2 2 No No No None
6/2/2018 Year 6-Period 1 1.90 Gray Light None 2 2 2 No No No None
11/15/2018 Year 6-Period 2 1.35 Gray Light None 2 2 2 No No No None
2/22/2019 Year 7-Period l 0.50 Gray I Light None 2 2 2 No No No None
12/6/2019 Year 7-Period 2 0.70 Blue/Gray Medium I None 4 2 1 2 No No No None
6/30/2020 Year 8-Period l 0.50 Gray Light None 2 2 F 2 1 No No I No None
11/12/2020 Year 8-Period 2 0.50 Gray Light None 2 2 2 No No No None
1/26/2021 Year 9-Period 1 0.75 Gray Light None 3 3 3 No No No None
7/8/2021 Year 9-Period 2 0.50 Gray Light None 3 3 3 No No No None
Year 10-Period 1 No measurable rainfall during work hours January 2022 through June 2022 None
11/11/2022 Year 10-Period 2 0.82 Gray Light None 3 3 3 No No No None

Fortress Wood Products
3874 Bethel Drive Extension
r-, High Point, North Carolina 27260
Best Management Practices
Best Management Practices(BMPs)are measures used to prevent or mitigate pollution from any
type of activity. BMPs may include processes,procedures, schedules of activity,restrictions on
practices,and other management practices to prevent or reduce water pollution.
Baseline BMPs are general common sense practices which are inexpensive,relatively simple and
applicable to a wide variety of industries and activities. The facility has implemented the
following baseline BMPs with emphasis on management practices that ensure continued vigilance
of proper facility operations and a methodology of inspections and oversight that continually
reviews the program to facilitate effective pollution prevention.
Good Housekeeping
Those areas of the facility which may contribute pollutants to stormwater discharges are
maintained in a.clean and orderly manner.All employees are trained in basic clean up procedures.
Waste media are collected for disposal on a regular basis.The floors of the kiln,stacker building,
and treatment area,as well as the ground surfaces are swept/cleaned on a regular basis.Material
storage areas are properly maintained and all containers are labeled in accordance with applicable
regulatory requirements.This BMP is addressed in more detail in Section 5.
Preventative Maintenance
Preventative maintenance inspections of facility equipment are conducted on a monthly basis to
ensure that all systems are working properly and to identify conditions(e.g. cracks,leaks,and
corrosion)which may cause breakdowns or failures.The most important areas for inspection are
the aboveground storage tanks.and associated above ground piping. Defective equipment, found
during inspections,is promptly repaired or replaced. The completed"Monthly Maintenance
Inspection"forms are maintained on-site in this plan. This BMP is addressed in more detail in
Section 5.
Visual Inspections
In addition to the"Monthly Maintenance Inspections"of plant systems and equipment,outdoor
storage areas to include loading/unloading and the storm water drainage system(including the
drainage swales and outfalis)are conducted semi annually."Facility Semi-Annual Stormwater
Inspection"forms are included in page 58 and copies of the completed forms are also maintained
on-site. The goal of these regular semi-annual inspections is to confirm that chosen Best
Management Practices for storm water pollution prevention are in place and working properly.
This BMP is addressed in more detail in Section 9.

Spill Prevention and Response
The area with the highest spill potential is the fuel deck which facilitates vehicle fueling. The
preventative maintenance/inspection programs outlined above are one of the most important
methods for spill prevention. They ensure that faulty equipment and deteriorating storage
containers are detected before a leak/release occurs. Good housekeeping practices also reduce the
potential for accidental pollutant releases, as it ensures that containers are properly stored and
maintained.Employees have also been trained in proper materials handling methods. Finally,in
order to prevent spills during loading/uploading,care is taken to ensure that all drums/containers
are tightly closed and handled appropriately.Any spills which occur at this facility is documented
and records are maintained on-site. This BMP is addressed in more detail in Section 4.
Sediment and Erosion Control
All undeveloped areas surrounding the plant,including the stormwater drainage swales,are either
planted with agricultural crops or grassed to prevent soil erosion. These areas are inspected semi-
annually(Facility Semi-Annual Stormwater Inspection)to ensure that erosion is kept at a
minimum and grass and/or appropriate vegetation is replanted if bare spots are observed
developing.
Management of Stormwater Runoff
Management of stormwater runoff is accomplished through practices that control and divert
stormwater in such a manner that natural filtration of stormwater runoff occurs which reduces the
concentration and amount of pollutants in stormwater discharge from the site. This is
accomplished through management practices which minimize outside inventory storage of treated
lumber,management of areas which provide exposure of other materials and operations,and
vigilance as to the healthy integrity of vegetation in and around stormwater swales and outfalls. In
this manner,exposure of pollutants is minimized and stormwater runoff can be managed in each of
the five stormwater outfalls to reduce flow velocity of the water. Reduction of flow velocity
combined with the flow of the water through large areas of vegetation provides the opportunity for
pollutants to disperse,dilute,and be naturally captured on site.
Employee Training
An employee training program is provided to inform personnel at all levels as to their
responsibility for assuring that the components and goals.of this S WPPP are upheld and complied
with.Employee training addresses each component of the S WPPP, including how and why tasks
are to be implemented. This BMP is addresses in detail in Section 6.
Recordkeeping and Reporting
Recordkeeping and reporting procedures are defined in various sections of this SWPPP and
Summarized in Section 9. The inspection,recordkeeping, and reporting program is established to
monitor pollution prevention practices,maintain storm water drainage areas,prevent spills and
leaks from reaching navigable waters,identify and document needed improvements,and define
responsibilities and communications in the event of a related emergency.

Activity-Based and Site-Specific Best Management Practice
Specific Best Management Practices(BMPs)for industrial activities which may contaminate
storm water include fueling, storage of treatment materials,outside storage for treated product,and
by-products of activities. Other site-specific BMPs consider storm water flow diversion,exposure
m. .*__ation practices,mitigation practices,and sedimentation and erosion prevention practices.
_T3Te of activity s ecific BMP Activity specific BAP employed
1.Tank stored in a bermed area.
Fueling 2.Dry sorbent material used to clean-up small spills.
3. Topping off of fuel tanks is discouraged.
1.Liquids and chemicals stored in tanks inside of the
treatment building where entire contents are contained by
the architectural construction of the building.
Treatment material storage 2.Tanker off-load area slanted to capture tanker leaks,
spills,and catastrophic events.
3.A mechanical dam/gate has been constructed on
Stormwater Outfall#2 as a secondary containment
strategy in the event of a catastrophic spill which
nu grates outside the treatment area.
1. Treated product inventory is minimized.
2. Treated material is dead packed and stacked in such a
Outside storage of treated product manner to minimize stormwater contact.
3. Treated material is placed on bolsters thereby avoiding
direct contact with the ground and stormwater.
,.•� 1. Water condensate from drying operations is collected
Activity by-products and recycled back into the treatment process.
Site-Specific BAPS Activity to mitigate pollution exposure
1.Fuel oil stored in closed tanks.
Exposure Minimization Practices 2.Fuel oil storage tanks cleaned as necessary.
Mitigation Practices 1. Fueling performed under supervision.
Sedimentation and Erosion Prevention 1. Drainage swales are grassed.
Practices 2. Sedimentation basin employed
BMP Assessment Impacted Area Activity to address assessment
Training Liquid Storage Training is part of this S WPPP
1. Swales have been dressed and planted
with vegetation. Additionally, rip-rap
(stone)has been placed in the swales.All
Drainage swales and swale manicuring has been done to assist
Stormwater Flow Control property egress in the filtering of the stormwater,control
of stormwater flow,and to assist in the
prevention of stormwater erosion.
Signage added at the fuel deck to remind
Signs Liquid Storage Fueling employees of housekeeping and pollution
r"`tI prevention policies.

Fortress Wood Products
3874 Bethel Drive Extension
High Point ,, North Carolina 27260
Short Narrative Describing Any Significant Changes at the
Permitted Facility
There have been no significant changes made at the permitted facility since the
last permit was issued.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program
Facility Name: F.ri wood PrpEacis
Permit Number: NCS wows
Location Address: w74 eemet om,e Extensbn
High P rtL Nortlt Catolbta 272w
County:
Randolph
"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."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit�p igtory requirements)and return this Certification. DO NOT
SEND STORMWATE O UTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date �-z0. 13
George M.Dickens,Jr President&CEO,The Lester Group
Print or type name of person signing above Title
SPPP Certification 10113