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Home My WebLink AboutNCS000456_Fact sheet binder_20230816 DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer/Date Brianna Young 8/14/2023 Permit Number NCS000456 Owner/Facility Name Culpeper of Cove City,LLC/Culpeper of Cove City SIC AICS Code/Category 2491 (321114)/Wood Preservation Basin Name/Sub-basin number Neuse/03-04-08 Receiving Stream/HUC UT to Core Creek/030202020601 Stream Classification/Stream Segment Q Sw,NSW/27-90 Is the stream impaired on 303 d list]? Yes Any TMDLs? No Any threatened and/or endangered species? See Section 2 below Any compliance concerns? See Section 2 below Any perinit mods since lastpermit? No New expiration date 8/31/2028 Comments on Draft Permit? See Section 6(below) Section 1. Facility Activities and Process: Culpeper of Cove City, LLC is a wood preservation facility. Treatment consists of chromated copper arsenate (CCA) (for commercial wood) or micronized copper azole (MCA) (for residential wood). Waters accumulated inside containment areas are used back in the process. All freshly treated lumber is kept under cover on a drip pad until drippage has ceased. There are several storage sheds where the majority of treated lumber is stored, and any remaining lumber is kept on the yard until sold. Oil or chemicals used at the maintenance department are kept inside the maintenance building or under cover. Any water accumulated within unloading containment is either pumped out, reused in the wood treatment process, or shipped for recycling if contaminated with oil. Outfall SW001: Drainage area consists of treated wood storage, hazardous waste storage, maintenance shop, treatment plant, chemical storage, fueling area and storage. Potential pollutants include: CCA, copper azole, diesel fuel, gasoline, motor oil, and hydraulic oil. 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 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 Page 1 of 6 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: • March 2017 to November 2022, benchmarks exceeded for: o TSS 3x o Copper 8x o pH min not reached 4x • Per the June 2023 inspection report: o This facility has several storage tanks of chemicals/pesticides used for its operations. There's a drainage ditch that wraps around the entire facility and stormwater runoff is routed through that ditch into a pond. o This facility also has a horizontal drum to store diesel covered under a shed and with a dyke wall. Insides of the dyke wall had oil stains up to a height of 2-3 feet all around the dyke. Outside the dyke oil mixed with mud/soil was found mopped and scraped off to the side of truck parking bay. It is suspected that there have been several oil spill incidents at this site evident from above indicators. It is recommended that safety person may be present during the loading/unloading operation of this diesel tank so as to be able to carry out necessary mechanical/procedural modifications. 303(d) listing: re Creek 27-90a2 ;s3nr,N5W FW Miles 8615 From upstream crossing of 5R 1239 to Grape Creek PARAIIIE7Hi IR CATEGORY CRITERIA STATUS REASON FOR RATING 303DYEAR Benthos[Nar,AL,FWJ 5-1 Exceed ing Criteria Fair,Poor or Severe Biodmification Threatened/Endangered Species: Regal Darner(Coryphaeschna ingens;NC status: SR), Phantom Darner(Triacanthagyna trifida; NC status: SR), and Banded Sunfish(Enneacanthus obesus;NC status: SR). Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for March 2017 to November 2022. Quantitative sampling included pH, TSS, arsenic, chromium, copper, COD, BOD, O&G, phosphorus, TKN, nitrate-nitrite, and hardness. 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 Culpeper of Cove City, LLC site. Page 2 of 6 Outfall SW001 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring H BASIS: Pollutant indicator and important to interpreting toxicity potential p of metals. 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 Total Arsenic BASIS: Potential pollutant from drainage area Quarterly monitoring Total Chromium BASIS: Potential pollutant from drainage area Quarterly monitoring Total Copper BASIS: Potential pollutant from drainage area Quarterly monitoring Total Hardness BASIS: Monitoring for hardness dependent metals 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 BPJ; Based on Secondary Treatment Regulation(40 CFR 133.03 COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Arsenic Total 340 /L Acute Aquatic Criterion, '/2 FAV '/2 FAV; Based on(Cr III+Cr VI) acute thresholds and Chromium(Total) 905 µg/L assumption that industrial activities here are not a source of hexavalent chromium Copper Total 10 /L I 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 • Feasibility study requirement removed per updated stormwater program requirements • eDMR requirement added • Boilerplate language moved into body of the permit; boilerplate no longer attached • Outfall-specific monitoring been implemented to reflect industrial activity and potential pollutants specific to each discharge area • Monitoring added for BOD and COD o Removed in previous permit as all values were below benchmarks Page 5 of 6 o These are indicators of issues with stormwater and pollutants of concern for the type of industry • Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals is required • Benchmarks updated for parameters per guidance from DWR Standards group on stormwater benchmarks Section 5. Changes from draft to final: • None Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility: 4/20/2023 • Initial contact with Regional Office: 4/20/2023 • Draft sent to CO peer review: N/A • Draft sent to Regional Office: 6/30/2023 • Final permit sent for supervisor signature: 8/14/2023 Section 7. Comments received on draft permit: • None Page 6 of 6 Affidavit of Publication STATE OF NORTH CAROLINA PUBLIC NOTICE NORTH CAROLINA BEAUFORT & HYDE COUNTIES ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE Ashley Vansant, being duly sworn, says: NPDES STORMWATER That he is Publisher of the Washington Daily News, DISCHARGE PERMITS a daily newspaper of general circulation, printed and The North Carolina published in Washington, Beaufort& Hyde Coun- Environmental Management ties, North Carolina;that the publication, a copy of Commission proposes to issue which is attached hereto, was published in the said NPDES stormwater discharge newspaper on the following dates: betl wi. Pub c p comment or objection to the draft permits is invited. Written comments regarding the proposed permit 07/08/23 will be accepted until 30 days after the publish date of this notice and considered in the That said newspaper was regularly issued and final determination regarding circulated on those dates. permit issuance and permit provisions. The Director of the NC Division of Energy,Mineral, The sum charged by the Newspaper for said publi- and Land Resources (DEMLR) cation does not exceed the lowest rate paid by com- may hold a public hearing should mercial customers for an advertisement of similar there be a significant degree size and frequency in the same newspaper in which of public interest. Please mail Q Ycomments and/or information the public notice appeared. requests to DEMLR at 1612 Mail Service Center, Raleigh, There are no agreements between the Washington NC 27699-1612. ? Culpeper of Dail News and the officer or attorney charged with City Cove, City, ,NC 2 Old Hwy Y y fd 70 W,Cove City,NC 28523)has the duty of placing the attached legal advertising requested renewal of permit notices whereby any advantage, gain or profit ac- NCS000456 for the Culpeper crued to said officer or attorney. county.Cove facility d 5 harges to an unnamed tributary to SIGNED: Core Creek in the Neuse River Basin. Interested persons may visit DEMLR at 512 N. Salisbury Street, Raleigh, NC 27604 to review information on file. Additional information on NPDES permits and this notice may be found on our website: https://deq.ne.gov/about/ divisions/energy-mineral-and- Ashley Vansant, Publisher land-resources/stormwater/ stormwater-program/ Subscribed and sworn to before me this stormwater-public-notices, or 8th Da Of July,2023 by contacting Brianna Young at Y Y bdanna.young@deq.nc.gov or 919-707-3647. y�o Esw� Washington Daily News: Jul.8,2023 � 2g NOTARY INTENT 9 NBLIC �r -td E J N E D rAflGE' Mary Jo Eskridge, Notary Public JUL 2 2023 State of Alabama at Large My commission expires 03-02-2026 �R-Sfom)wa#er Program Account#304614 Ad# 1672424 NCDEQ 1612 MAIL SERVICE CENTER RALEIGH NC 27699 Compliance Inspection Report Permit:NCS000456 Effective: 10/01/18 Expiration: 09/30/21 Owner: Culpeper of Cove City LLC SOC: Effective: Expiration: Facility: Culpepper of Cove City County: Craven 11065 Old Hwy 70 W Region: Washington Cove City NC 28523 Contact Person:Josh Adkins Title: Phone: 803-566-3270 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 06/13/2023 Entry Time 01:OOPM Exit Time: 03:OOPM Primary Inspector:William J Moore Phone: 252-946-6481 Ext.264 Secondary Inspector(s): Varun Prakash Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCS000456 Owner-Facility:Culpeper of Cove City LLC Inspection Date: 06/13/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection was conducted on 06/13/2023. Met with Josh Adkins, Director of Environment and Safety(M:(803)-566-3270, email:jadkins@culpeperwood.com)at around 1 pm. This facility has SIC code 2491 and carries out the following wood treatment operations: 1. treats residential wood using a chemical MCA(Micronized CopperAzole), and 2. treats commercial wood using a chemical CCA(Chromated copper arsenate). This facilty has several storage tanks of chemicals/pesticides used for its operations. There's a drainage ditch that wraps around the entire facilty and stormwater runoff is routed through that ditch into a pond(has state SW permit SW7040514). This site has several open wood storage locations,along with vegetative buffer all around the operating area. This facility also has a horizontal drum to store diesel covered under a shed and with a dyke wall. Insides of the dyke wall had oil stains upto a height of 2-3 feet all around the dyke. Outside the dyke oil mixed with mud/soil was found mopped and scraped off to the side of truck parking bay. It is suspected that there have been several oil spill incidents at this site evident from above indicators. It is recommended that safety person may be present during the loading/unloading operation of this diesel tank so as to be able to carry out necessary mechancal/procedural modifications. It is recommended that permit number NCS000456 may be reissued. Page 2 of 3 Permit: NCS000456 Owner-Facility:Culpeper of Cove City LLC Inspection Date: 06/13/2023 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: This facility also has a horizontal drum to store diesel covered under a shed and with a dyke wall. Insides of the dyke wall had oil stains upto a height of 2-3 feet all around the dyke. Outside the dyke oil mixed with mud/soil was found mopped and scraped off to the side of truck Parking bay. It is suspected that there have been several oil spill incidents at this site evident from above indicators. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑ Comment: 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: 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 Young, Brianna A From: Adkins,Josh <jadkins@culpeperwood.com> Sent: Friday, April 21, 2023 4:10 PM To: Young, Brianna A Subject: [External] RE: Culpeper of Cove City, LLC (NCS000456) Attachments: Cove City Stormwater.xls CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good afternoon, See below in red. Please let me know if you have any other questions. • Payment of the overdue permit annual fee. A copy of the invoice is attached to this email; This has been taken care of by credit card. • Description of industrial activity occurring onsite and chemicals used/stored; Activity: Wood Preservation. Untreated lumber is brought on site for treatment using a copper based (micronized) amine formula or an inorganic arsenial(CCA). All chemicals used in the treatment process are kept inside containment areas. Waters accumulated inside these containment areas are used back in the process. All freshly treated lumber is kept under cover, on a RCRA Subpart W drip pad until drippage has ceased. There are several storage sheds where we store as much of the treated lumber as possible (around 6501o). Any remaining lumber is kept on the yard until sold. Chemicals used: (CCA) Chromium Copper Arsenic, Micronized Copper, Diesel Fuel, Gasoline, Motor Oil, Hydraulic Oil. Any oil or chemicals used at the maintenance department are kept inside the maintenance building or under cover. All bulk oil tanks have secondary containment and is roofed, along with drip pans under the nozzles. A diesel unloading containment area has been installed by the diesel tanks. Any water accumulated within this unloading containment is either pumped out, reused in our wood treatment process, or if contaminated with oil, is shipped for recycling. • Confirmation on the number of outfalls and associated coordinates; Number of outfalls: 1 Lattitude: 35.189720 Longitude: -77.336390 • Description of industrial activity in each drainage area; Activity at Drainage area: Lumber storage • SIC (NAICS) code; NAICS: 321114 • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; See attached spreadsheet • Verification that the information in the renewal application is still complete and correct; Everything is still complete and correct. i • An explanation of any operational changes since the renewal application was submitted. No operational changes since renewal application was submitted. Josh Adkins Director of Environmental and Safety CWP - Orangeburg I www.culpeperwood.com aadkins@culpeperwood.com P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367 CULPEPER WOOD PRESERVERS The Trusted Brand in Pressure Treated Lumber From: Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Thursday,April 20, 2023 3:09 PM To:Adkins,Josh <jadkins@culpeperwood.com> Subject: Culpeper of Cove City, LLC (NCS000456) You don't often get email from brianna.young@ncdenr.gov. Learn why this is important CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe!!! Good afternoon, I am working on renewing the individual stormwater permit for Culpeper of Cove City, LLC (NCS000456). 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: • Payment of the overdue permit annual fee. A copy of the invoice is attached to this email; • Description of industrial activity occurring onsite and chemicals used/stored; • Confirmation on the number of outfalls and associated coordinates; • Description of industrial activity in each drainage area; • SIC (NAICS) code; • 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. 2 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 og ulias • Stormwater outfall information: Email Bethany Georgoulias • Visit the eDMR Six Steps website and complete Steps 1 and 2. • Pay outstanding permit fees: Stormwater ePgMent 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 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 e:,,- D E '�7'� NORTH CAROLINA ClAi Department of Environmental Quality 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. 3 4 Young, Brianna A From: Adkins,Josh <jadkins@culpeperwood.com> Sent: Friday, April 21, 2023 4:04 PM To: Young, Brianna A Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Thank you. We will submit a modification request once the site layout is complete. I will submit the answers to the questions in the original email shortly. Josh Adkins Director of Environmental and Safety CWP - Orangeburg I www.culpeperwood.com jadkins@culpeperwood.com P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367 CULPEPER WOOD PRESERVERS The Trusted Brand in Pressure Treated Lumber From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Friday,April 21, 2023 1:54 PM To:Adkins,Josh <jadkins@culpeperwood.com> Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456) CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe!!! As you are not certain at this time what the final plan will be, and the completion date is quite a ways off, I recommend moving forward with the permit renewal and submitting a modification request later when you know the final site layout. Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) 1 Brlanna.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:Adkins,Josh<jadkins@culpeperwood.com> Sent: Friday,April 21, 2023 1:32 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. We really won't know for certain until we finish clearing and grading the property, but it looks like we may possibly have to add at least one more outfall.The only industrial activity will be lumber storage. Josh Adkins Director of Environmental and Safety CWP - Orangeburg I www.culpeperwood.com jadkins@culpeperwood.com P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367 ,0,00,&PIA06'e"t,4-'001ap'li. CULPEPER WOOD PRESERVERS The Trusted Brand in Pressure Treated Lumber From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Friday,April 21, 2023 12:21 PM To:Adkins,Josh<jadkins@culpeperwood.com> Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456) CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe!!! 2 Hello Josh, Thank you for the prompt payment and response. In regards to the land clearing—will this be a new outfall that needs to be added to the permit?Or will the drainage from the new area go to an existing outfall?Will the only industrial activity on the site be lumber storage, or will other operations occur as well? 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) Brlanna.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:Adkins,Josh<iadkins@culpeperwood.com> Sent: Friday,April 21, 2023 10:25 AM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: [External] RE: Culpeper of Cove City, LLC(NCS000456) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good morning, I have taken care of the permit annual fee by credit card, see attached receipt.Apparently it got submitted to our accounts payable department but never got paid. I updated the billing address this morning so the bill will be sent directly to one of our corporate offices. I also have one question before I submit the answers to the questions below. We are in the process of clearing a parcel of property bordering our current facility.This new parcel of land will be used for lumber storage. At this point we are still working to clear the property so would it be best to continue the renewal and submit the modifications at a later date for the new property or should we hold off on the renewal and submit the changes with the renewal? It's likely to be 6 to 8 months before we are complete with the clearing and grading of the new property. Josh Adkins Director of Environmental and Safety 3 CWP - Orangeburg I www.culpeperwood.com iadkins@culpeperwood.com P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367 CULPEPER WOOD PRESERVERS The Trusted Brand in Pressure Treated Lumber From: Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Thursday,April 20, 2023 3:09 PM To:Adkins,Josh<iadkins@culpeperwood.com> Subject: Culpeper of Cove City, LLC (NCS000456) Good afternoon, I am working on renewing the individual stormwater permit for Culpeper of Cove City, LLC (NCS000456). 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: • Payment of the overdue permit annual fee. A copy of the invoice is attached to this email; • Description of industrial activity occurring onsite and chemicals used/stored; • Confirmation on the number of outfalls and associated coordinates; • Description of industrial activity in each drainage area; • SIC (NAICS) code; • 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 og ulias • Stormwater outfall information: Email Bethany Geor og ulias 4 • 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 Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.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 ID: 7 �E 'A Orperlm O W E(MronrnaMal 4ualdy 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. 5 Cove City Outfall 001 Permit#NCS000456 LI)Q t _ 06O Y rL O y r= cn o Q to a L O 0 ~ Z Z M U a 2 Benchmrk 1 100 0.36 1 0.007 120 30 6-9 30.00 2 ? 30 mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I su mg/I mg/I mg/I mg/I Mar-17 100 0.043 0.36 0.059 1 0.0820 0.007 46 120 3.4 7.47 BDL 0.44 1 0.15 Dec-17 100 0.026 0.36 0.035 1 0.1300 0.007 38 120 2.8 7.64 BDL 0.28 0.79 5 Jul-18 47 100 0.003 0.36 0.0029 1 0.0150 0.007 54 120 4 8.10 BDL 0.2 1.3 2 Dec-18 14 100 BDL 0.36 0.001 1 0.0049 0.007 BDL 120 BDL 7.96 BDL 0.083 1.1 5.2 May-19 100 0.062 0.34 0.220 1 0.1600 0.01 50 120 20 7.30 2.50 0.23 1.6 0.23 300 BDL = Below detectable level Aug-19 32 100 BDL 0.34 BDL 1 0.0040 0.01 32 120 BDL 7.10 BDL 0.10 0.61 0.45 110 Mar-20 5.4 100 BDL 0.34 0.0019 1 0.0320 0.01 BDL 120 4.6 7.00 2.20 0.22 3.7 1.8 92 Sep-20 25 100 0.005 0.34 0.003 1 1 0.05201 0.01 27 1 120 4.5 6.90 BDL 0.17 0.70 0.79 76 Sep-20 14 100 BDL 0.34 0.001 1 0.01 0.01 27 120 2.7 5.80 BDL 0.19 1.20 4.8 58 :Monthly DueOct-20 6.8 100 BDL 0.34 BDL 1 0.01 0.01 31 120 2.1 5.60 3.50 0.10 1.40 9 88 HighNov-20 7 100 BDL 0.34 0.001 1 0.0015 0.01 56 120 5.4 5.90 BDL 0.15 1.50 4 46opper Jun-21 11 100 BDL 0.34 BDL 1 BDL 0.01 36.00 120 BDL 5.90 2.10 0.10 1.60 12 64 Dec-21 18 100 BDL 0.34 0.009 1 1 1 0.002 1 0.01 135.001 120 1 5.70 6.80 4.10 0.23 1.20 3.8 82 4/20/23, 1:13 PM 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 Limited Liability Company Legal Name Culpeper of Cove City, LLC Information Sosld: 1668590 Status: Current-Active O Date Formed: 2/20/2018 Citizenship: Foreign State of Incorporation: VA Annual Report Due Date: April 15th Currentgnnual Report Status: Registered Agent: Corporation Service Company Addresses Reg Office Reg Mailing Mailing 2626 Glenwood Ave Ste 550 2626 Glenwood Ave Ste 550 501 N Main Street Raleigh, NC 27608 Raleigh, NC 27608 Culpeper, VA 22701 Principal Office 501 N Main Street Culpeper, VA 22701 Company Officials All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20. Secretary Chief Executive Officer President Doris Batiste Joseph R. Daniel Joseph R Daniel Jr 501 N Main Street 501 N Main Street 501 N Main Street Culpeper VA 22701 Culpeper VA 22701 Culpeper VA 22701 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2 4/20/23, 1:13 PM North Carolina Secretary of State Search Results https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2 Young, Brianna A From: Young, Brianna A Sent: Monday, April 10, 2023 2:14 PM To: jadkins@culpeperwood.com Subject: Culpepper of Ramseur(NCS000452) and Culpepper of Cove City(NCS000456) Good afternoon, The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program acknowledges receipt of your renewal applications for coverage under NPDES Permit Number NCS000452 and NCS000456. Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater permits. As long as you have submitted a complete renewal request package and maintain compliance with those permit conditions, stormwater discharges from these facilities are authorized by that permit until the Division issues a renewal permit or notifies you of an alternative action. Please let me know if you have any questions in the interim. 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 z_..-��D_ E '�&'� ti ; NORTH CAROLINA Department of Environmental Quality 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. 1 Permit Coverage Renewal ARDlication Form National Pollutant Discharge Elimination System NP Permit Number NCS 000456 Environmental Stormwater Individual Permit Quality 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 * Address to which permit correspondence will be mailed Owner/ Organization Name: Culpeper of Cove City,LLC Owner Contact: Josh Adkins P r T I V�C D Mailing Address: 11065 Old Hwy 70 W,Cove City,NC 28523 ✓I �. 11065 Old Hwy 70 W,Cove City,NC 28523 MAR 10 2021 .� 1�V-(CCJJ Phone Number: 803-566-3270 PENR-LAND QUALITY Fax Number: 4EIRUih!ATER PERilITTING E-mail address: jadkins@culpeperwood.com Facility Information Facility Name: Culpeper of Cove City,LLC Facility Physical Address: 11065 Old Hwy 70 W,Cove City,NC 28523 Facility Contact: Josh Adkins Mailing Address: 11065 Old Hwy 70 W,Cove City,INC 28523 Phone Number: 803-566-3270 Fax Number: E-mail address: jadkins@culpeperwood.com Permit Information Permit Contact: Josh Adkins Mailing Address: 11065 Old Hwy 70 W,Cove City,NC 28523 Phone Number: 803-566-3270 Fax Number: E-mail address: jadkins@culpeperwood.com Discharge Information Receiving Stream: Core creek Stream Class: C;Sw,NSW Basin: Neuse Sub-Basin: 03-04-08 Number of Outfalls: 1 Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a separate sheet if necessary. No significant changes. CERTIFICATION I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, cplete and accurate. Signature Date 03/03/2021 4J.shdkins E&S Director Print or type name of person signing above Title Please return this completed application form DEMLR- Stormwater ProgramDept. of Environmental Quality 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 JA 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. JA 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. JA 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. J A 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. JA 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. JA 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) CULPEPER OF COVE CITY, LLC Craven County Permit#NCS000456 Treated Wood StorageHazardous Waste Storage y 4 ' t - 7 v� !'" f ![F. " � � �•. �_. � � ��.. Outfall (UT—Core Creek) Stream Class C;SWG NSW _ .. �, u ' +�a,r. , Neuse ► '' ` 35.189895 N 77.336468 W DCA TP � Ditch surrounds property. Property has underground drainage system to pond. Water flows to pond or ditch, which meet at outfall M = Maintenance Shop Area TP =Treating Plant, chemical storage F= Fueling area and storagewy E= Evacuation Meeting Location r- f Cove City Outfall 001 Permit#NCS000456 L- f/) E Q 0 o Z o ham- N E 0. () 0 Q O N Y N Q U U m t ~ z z n3 a 2 Benchmrk 100 0.36 1 0.007 120 30 6-9 30.00 2 ? 30 mg/I mg/l mg/I mg/l mg/I mg/l mg/I mg/I mg/l mg/I mg/l su mg/I mg/I mg/I mg/l Jul-18 47 100 0.003 0.36 0.0029 1 t�.C1'd:_b 0.007 54 120 4 8.10 BDL 0.2 1.3 2 Dec-18 14 100 BDL 0.36 0.001 1 0.0049 0.007 BDL 120 BDL 7.96 BDL 0.08 1.1 5.2 May-19 170 100 0.062 0.34 0.220 1 0.1600 0.01 50 120 20 7.30 2.50 0.23 1.6 0.23 300 Aug-19 32 100 BDL 0.34 BDL 1 0.0040 0.01 32 120 BDL 7.10 BDL 0.10 0.61 0.45 110 Mar-20 5.4 100 BDL 0.34 0.0019 1 0.0320 0.01 BDL 120 4.6 7.00 2.20 0.22 3.7 1.8 92 Sep-20 25 100 0.005 0.34 0.003 1 0.0520 0.01 27 120 4.5 6.90 BDL 0.17 0.70 0.79 76 Sep-20 14 100 BDL 0.34 0.001 1 0.01 0.01 27 120 2.7 5.80 BDL 0.19 1.20 4.8 58 Monthly Due Oct-20 6.8 100 BDL 0.34 BDL 1 0.01 0.01 31 120 2.1 5.60 3.50 0.10 1.40 9 88 to High Nov-20 7 100 BDL 0.34 0.001 1 0.0015 0.01 56 120 5.4 5.90 BDL 0.15 1.50 4 1 46 Copper Cove City Visual Inspections Outfall 01 Permit# NCS000456 Other Floating Suspended Obvious Color Odor Clarity Solids Solids Foam Oil Sheen Indicators 07/24/18 None None Clear No No No No None 12/20/18 None None Cloudy No No No No None 05/31/19 None None Clear No No No No None 08/23/19 None None Clear No No No No None 03/23/20 None None Clear No No No No None 09/11/20 None None Clear No No No No None 09/30/20 None None Clear No No No I No I None 10/26/201 None None Clear No No No No None 11/13/201 None None Clear No No No No None CULPEPER OF COVE CITY, LLC CRAVEN COUNTY PERMIT# NCS000456 SIGNIFICANT CHANGES There have been no significant changes to our process or chemicals over the years with one exception. Historically this facility operated both treatment areas using an inorganic arsenical wood preservative. One treatment area has been converted to a non-arsenical copper-based preservative for residential use. BEST MANAGEMENT PRACTICES The purpose of the SWPPP is to identify potential sources of pollution or contamination that originate at this facility, and to select and implement actions which prevent or minimize the release of pollutants into the storm water. The storm water management controls included in the SWPPP focus on providing adequate control of pollutant discharges with practical approaches that utilize readily available techniques, expertise, material and equipment. The SWPPP is intended to be a flexible, active operations plan to allow incorporation of changes and management practices. As the plan is implemented and methods to improve the plan are found, or as regulations change, revisions to the plan must be made. Revisions to the plan must be approved by management and recorded in all copies of the plan in order to meet the requirements of the storm water permit. This is a wood preservation facility. Untreated lumber is brought on site for treatment using either an inorganic arsenical (CCA) or a copper based (copper azole) amine formula. All chemicals used in the treatment process are kept inside containment areas. Waters accumulated inside these containment areas are used back in the process. All freshly treated lumber is kept under cover, on a RCRA Subpart W drip pad until drippage has ceased. There are several storage sheds where we store as much of the treated lumber as possible. Any remaining lumber is kept on the yard until sold. Forklifts and other vehicles are regularly inspected and maintained by the maintenance department. All maintenance work is done under cover. Any oil or chemicals used at the maintenance department are kept inside the maintenance building or under cover. All bulk oil tanks have secondary containment and is roofed, along with drip pans under the nozzles. A diesel unloading containment area has been installed by the diesel tanks. Any water accumulated within this unloading containment is either pumped out, reused in our wood treatment process, or if contaminated with oil, is shipped for recycling. At this time, based upon a review of our current procedures for reducing or eliminating exposure of materials to storm water, we have determined that it is not economically feasible to modify our program. We have our maintenance area inside a building, all oil tanks in secondary containment, all chemicals in secondary containment or under cover and numerous sheds to store lumber in. The lumber stored outdoors is dry, stacked to minimize exposure and inventory controlled to reduce potential exposure to a rain event. Housekeeping procedures are in place to regularly remove debris in the yard and inspect around our maintenance and treating plant for chemical contamination. BEST MANAGEMENT PRACTICES -MEASURES AND CONTROLS The results of a site assessment indicate that controls are either in place or need to be added to minimize contaminant releases to storm water runoff. Housekeeping is one area that can be readily controlled to limit the discharge of wood debris and minimize the generation of dust. Best Management Practices (BMPs) as well as other controls are used to reduce potential contaminant releases. Some of our controls are as simple as ensuring that we maintain vegetation, such as grass on slopes to prevent soil erosion and keeping outfall areas clean and free of debris. Culpeper of Cove City, LLC—Craven County Page 1 of 5 Permit#NCS000456 All chemical bulk storage tanks are within secondary containment. None of our secondary containment structures have any type of drainage system. Only personnel placing a pump into the diesel containment area can remove liquid. This method prevents any release of oil from our containment system due to rain. Our chemical storage containment areas that are not located inside a building have automatic pumps that will pick up liquid and place it into a bulk storage tank located within a containment area. This liquid is then used in our treating processes. Most hose as well as the trailer connection section is inside a containment area. If any tank or hose connections would have to be outside the contained area due to an unusual circumstance, each connection would have a bucket underneath to catch drips and minor leaks. A qualified employee with access to the proper safety equipment approves the hook up to our tank prior to unloading and monitors the loading and unloading process. All non-bulk containers, such as drums, are stored either indoors or within a contained area. Finished lumber products are stored under sheds or in the yard until shipment. The lumber trucks are loaded over asphalt or gravel areas. Prior to storing any treated lumber outdoors,verification that there is no drippage has been documented. The drip pads are under roof and bermed/sloped to prevent any release. Any liquid generated from drippage or a rain event flows to a sump and then is automatically picked up and place into an effluent tank. Visual, as well as some documented Inspections are regularly performed on the drip pad and maintenance, such as sealing or cracks and coating replacement, is performed as needed. All cutting of lumber is currently performed outdoors. Since this is a wood preservation facility and not a planer or sawmill, very little sawdust is generated due to the cutting of lumber. Typically, the total amount generated during a cutting would be a pile less than 2' by 2'. Frequency of cutting is one or two times weekly. This operation is pre-scheduled so cutting is not performed during a rain event and the sawdust and debris is picked up from the Holtech Saw immediately and placed in containers. There is also a small saw operation used once or twice weekly to cut a few pieces of lumber. The pile generated is generally less than 1' by 1' on a concrete pad. The sawdust is disposed of as a non-hazardous waste. Various types of equipment associated with this wood preserving facility include but are not limited to pressure retorts, mechanical pumps, fueling trucks, maintenance equipment, freight transfer vehicles, construction equipment and forklifts. Trucks, trailers, and forklifts are cleaned in an enclosed, roofed area designed for this purpose. The water is reclaimed through an oil water separator. It is recognized that maintenance of vehicles can be a significant source of storm water pollutants. Materials associated with vehicle maintenance include waste oil, solvents and other degreasers, brake fluid, anti freeze, battery acids, radiator flush, and sludge. The following vehicle maintenance practices are utilized: - Maintenance is completed in an enclosed area protected from runoff and precipitation whenever possible. If maintenance has to be performed outside of the enclosed area, all possible means are used to prevent spillage and approved cleaning methods (oil dry, etc)are used if any spillage occurs. - All used products are properly stored until they are sent for recycling or disposal. - Batteries, used tires, and used solvents are collected and recycled through the appropriate vendors (Typically batteries are recycled immediately, so there is minimal to no storage). Culpeper of Cove City,LLC—Craven County Page 2 of 5 Permit#NCS000456 A feasibility review to determine if there is a way to modify or change our operating procedures or install controls to further reduce chemical exposure indicates the following: o Non-bulk chemical containment—All non-bulk chemicals are currently stored in secondary containment areas or under roof. o Chemical unloading—Chemical unloading is performed under roof or in containment areas that will allow the end of the trailer to be placed within this containment. Most hose connections at the tanks for bulk loading or unloading are inside the bulk storage containment area. Any tank or hose connections outside the contained area would have buckets underneath to catch drips and minor leaks. A qualified employee with access to the proper safety equipment approves the hook up to our tank prior to unloading and monitors the loading and unloading process. o Chemical containment—All chemicals are currently stored in secondary containment systems that cannot release without manual pumping. o Particulate containment—Generation of sawdust is currently performed outdoors. Since these procedures are used infrequently and can be pre-scheduled to ensure we do not release particulates during a rain event, at this time there is no need to change our procedures or modify the location. Sometime in the future, if there is an increase in the cutting of lumber, then moving or enclosing the saw areas will be addressed. o Diesel storage—The diesel tanks used to fuel lifts and tractors are located within a secondary containment system that cannot release without manual pumping. Filling the tank and fueling procedures are performed just outside the containment area. Current procedures and training are in place to prevent a release on the ground as well as emergency equipment availability at the diesel area to handle a release immediately to prevent rain event contamination. At some point in the future, we will look at changing the diesel storage area to prevent rain from accumulating inside the containment area. o Treated wood storage—Treated lumber is typically stored outdoors. Prior to placing the treated lumber outdoors, the material is documented that all drippage has ceased. This procedure should ensure that there is minimal release of chemicals during a rain event from the treated lumber. The lumber is also not placed directly on the ground, but stored 2-6" above to prevent contact. To ensure that the BMPs and other controls are in use and working, employees are taught about controls in use and periodic inspections are performed. The measures currently in use or to be implemented at our facility to control contaminant releases are found under section 4.a. Culpeper of Cove City,LLC-Craven County Page 3 of 5 Permit#NCS000456 4.a. Effective Pollutant control Options for Timber Product Facilities Activity Associated BMPs In Use Remarks Lumber, and Divert Storm water around storage areas with ditches, X other Wood swales and/or berms Product Storage Locate storage areas on stable,well-drained soils with X 80%of yard Areas slope of 2-5 percent (Untreated) Line storage areas with crushed rock, gravel or porous X pavement to promote infiltration, minimize discharge and provide sediment and erosion control Stack materials to minimize surface area of materials X Sheds are in exposed to precipitation use also Frequent removal of debris X Provide collection of runoff with containment basins, sedimentation ponds and infiltration basins X Activity Associated BMPs In Use Remarks Residue Storage Locate storage residues away from drainage pathways X Areas and surface waters (such as Avoid contamination of residues with oil,solvents, X untreated chemically treated wood,trash, etc. sawdust, chips) Assemble piles to minimize surface area of materials X exposed to precipitation Limit storage time of residues to prevent degradation X and generation of leachates Place materials on raised pads of compacted earth, clay, X shale, or stone to collect and drain runoff Limit slopes of storage areas to minimize velocities of X runoff which may transport residues Activity Associated BMPs In Use Remarks Loading and Provide diversion berms and dikes to limit runon X Unloading, Material Provide good housekeeping measures to limit debris and X Handling Areas to provide dust control Activity Associated BMPs In Use Remarks Wood Extend drip time on drip pad (process area) before X Preservation moving to storage Activities Pave and berm areas used by equipment that has come in X contact with treatment chemicals Locate treatment chemical loading and unloading areas X away from high traffic areas where tracking of the chemical may occur. Provide frequent visual inspections of loading and X unloading areas during and after activities occur to identify any spills or leaks needing clean-up Cover and/or enclose treatment areas X Elevate stored, treated wood products to prevent contact X Heavy retention with runon/runoff undershed Provide collection of runoff with containment basins, X sedimentation ponds and infiltration basins for treated wood storage areas Culpeper of Cove City,LLC—Craven County Page 4 of 5 Permit#NCS000456 Activity Associated BMPs In Use Remarks Chemical Provide secondary containment around chemical storage X Storage Areas areas Provide level gages X Inventory fluids to identify leakage X Locate storage areas away from high traffic areas and X surface waters Develop spill prevention, containment and X countermeasure SPCCplans and implement Cover and/or enclose chemical storage areas X Provide containment to allow for recycling of spill and X leaks Activity Associated BMPs In Use Remarks Equipment Provide diversion berms and dikes to limit runon X and/or vehicle maintenance Preventative maintenance program (cleaning oil/water X and cleaning separators, catch basins, vehicle mounted drip containment devices Minimizing storm water runon and runoff at fueling areas. X Perform all maintenance activities indoors X Cover and/or enclose chemical storage areas (used oil, X oil filters, used solvents, etc. Locate storage areas away from high traffic areas X Activity Associated BMPs In Use Remarks Erosion and Grassed areas to prevent soil erosion X Sediment Controls Use of vegetation on sloped areas to prevent sediment X run-off Ditches around property to prevent water run on from X neighboring locations Sediment Trap(Such as rock,vegetation, etc.) X Culpeper of Cove City,LLC—Craven County Page 5 of 5 Permit#NCS000456 CULPEPER OF COVE CITY, LLC COVE CITY, NC PERMIT# NCS000456 INDUSTRIAL ACTIVITY SIGNIFICANT CHANGES This facility is still operating with no significant changes from the previous permit application. They are still using the same wood preservative and have not added any new equipment. STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program Facility Name: Culpeper of Cove City,LLC Permit Number: NCS000456 Location Address: 11065 Old Hwy 70 W,Cove City,NC 28523 County: Craven "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 signatory requirements) and return this Certification. DO NOT SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION. Signature 4C Date 03/03/2021 Josh Adkins E&S Director Print or type name of person signing above Title SPPP Certification 10/13