The URL can be used to link to this page

Home My WebLink AboutNCS000566_Rescission request_20231019 Environmental Solutions and Strategies, LLC R O. Box 4244 Martinsville, Virginia 24115 '� VO October 14, 2023 � IRSto '��ate[ CERTIFIED MAIL— RETURN RECEIPT 70210350 0000 97201858 DEMLR - Stormwater Program Department of Environmental Quality 1612 Mail Service Center Raleigh, North Carolina 27699-1612 RE: Rescission of NPDES Permit NCS000566/Fortress Wood Products/Randolph County Dear DEMLR Please find enclosed the completed and executed Rescission Request Form for The Lester Group—Fortress Wood Products Randolph County operations, NPDES Permit Number NCS000566, for stormwater discharge. Should you have any questions, comments, concerns, or need for additional information, with regard to this matter, please contact me by e-mail at dmaddox@comcast.net, by telephone at 276-806-0178, or by facsimile at 276-632-3176. Thanking you in advance with regard to this matter, l remain, Sincerely, David P. Maddox President/CEO Environmental Solutions and Strategies, LLC C: ES' Files Fortress Wood Products—High Point Files FOR AGENCY USE ONLY Assigned to: ARO FRO MRO RRO WARO WIRO WSRO Division of Energy, Mineral, and Land Resources Land Quality Section National Pollutant Discharge Elimination System Rescission Request Form Please fill out and return this form if you no longer need to maintain your NPDES stormwater permit. Directions: Print or type all entries on this application form. Send the original, signed application to: NCDEMLR Stormwater Program, 1612 Mail Service Center,Raleigh,NC 27699-1612. The submission of this form does not guarantee recission of your NPDES stormwater permit. Prior to the recission of your NPDES stormwater permit, a site inspection will be conducted. 1. Owner/Operator(to whom all permit correspondence will be mailed): Name of legal organizational entity: Legally responsible person as signed in Item(4)below: Street address: City: State and zip code: Telephone number: Email address.. nr 2. Industrial Facility (faciljl,-.y equesting rescission)': hY ' ' Facility name Street address: "._ .< •c,�i�� 3�E"T`jG�`/ � �iYE' �.� �E.tf.��l�it/;" City- State: Zip Code: County Permit Number to which this request applies: 3. Reason for rescission Request This is required information, Attach separate sheets if necessary. E3 Facility is closed or closing.All industrial activities have ceased such that no discharges of stormwater are contaminatedz by exposure to industrial activities or materials. Date closed/closing: l2 Facility sold. Sold to: On date: ` Other(please explain): . . t 4. Applicant Certification: North Carolina General Statute 143-215.66(i) provides that: Any person who knowingly makes any false statement, representation,or certification in any application, record, report, plan,or other document filed or required to be maintained under this Article or a rule implementing this Article. . .shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars($10,000). 1 hereby request exclusion from NPDES stormwater permitting. Un r penalty of law, I certify that: I,as an authorized representative, hereby request recission of coverage under the NPDES stormwater Permit for the subject facility. I am familiar with the information contained in this request and to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Title: G FJ (Signature of Applicant) (Date Signed) Mail the entire package to: DEMLR--Stormwater Program Department of Environmental Quality 1612 Mail Service Center Raleigh, NC 27699-1612 Page 2 of 2 ES2 Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville Virginia 24115 October 11, 2023 Division of Energy, Mineral, and Land Resources Land Quality Section National Pollutant Discharge Elimination System Rescission Request Form NC DEMLR STORMWATER PROGRAM 1612 Mail Service Center Raleigh, North Carolina 27669-1612 Please find the following written comments pertaining to Part 3. Reason for rescission Request The facility and all adjoining property were originally constructed, and have remained the same without change, for stormwater discharges from the facility and property, in that, stormwater discharges were designed to be captured into two retention ponds, known as the upper pond and the lower pond, (topographical satellite photographs attached). The upper pond is a small retention pond located to the east of the main retention pond and collects water from a ditch running from the asphalt access road to the facility along Bethel Drive and along the eastern side of the property line, as shown in the satellite photos submitted with the permit application.The coinciding purpose of the upper retention pond is to provide a means for protection from unwanted property erosion, since the entire area the ditch transverses is to the east and significantly up gradient from all facility operations and storage areas, making this area of facility property subject to significant erosion over time_ For these reasons, this ditch does not collect any water(s)from facility operations but stormwater runoff from the asphalt road to the facility. Any water(s) not contained by the upper retention pond drains slowly down gradient into the large lower retention pond. All undrained water collected in the small upper retention pond is left to evaporate back to the atmosphere. All stormwater from operational and storage parts of the facility is directed to, and, exits these areas though Outfall SWO01 into the large lower retention pond, also shown in the photos provided with this rescission request. If a stormwater event, or multiple stormwater events overwhelm the containment ability of the lower retention pond, the excess water overflows this retention pond directly onto the owner's property where waters from stormwater events are fully contained and allowed to sheet across the forested topography of the facility property. NC DEMLR—Permit Rescission—Fortress Wood Products, LLC October 11, 2023 Page 2 of 3 As shown in the satellite photos,the stormwater discharge system for the facility and all adjoining properties of the facility, are designed to mitigate damage to the property from stormwater events, direct the stormwater in a manner where the stormwater can be managed and to provide allowances for excessive stormwater to either be retained on property by retention ponds whereby the water can naturally evaporate,or released onto the owners property where it is completely contained and allowed to naturally sheet and evaporate across the forested property.The satellite photos clearly show the sheeting area is fully contained on site by an elevated rail system to the west of the property line and elevated paved access roads to the east of the property line.The topography of the site property does not allow for any migration of stormwater from the property via the north or south due to continuous increases in land elevations. Additionally, Environmental Solutions and Strategies, LLC"ES211,the environmental consulting firm for The Lester Group,owners of fortress Wood Products,LLC, has walked the entire property acreage on multiple occasions, during non-rain events and rain events and has not been able to discover a means of egress of water from the property during a stormwater event.Additionally, ES2 has closely examined available information on the internet and on topographical maps and cannot find nor determine any unnamed tributary which NC DEMLR can connect the stormwater from this property site. In a May 3, 2023 "Certified Letter", sent from ES2 to the NC DEMLR, during the Draft Permit comment period,ES2 posited the question"Can NC OEMIIt provide EV evidentiary proof that an "unnamed tributary"exists that directly provides the conduit which water actually travels from the site property to Hunts Fork? Also,on Page 14 of 35 of the draft permit,the following comments were made. Outfall SW001:Drainage area includes the treated lumber storage area, loading and unloading areas,fuel AST, treatment buildings, detention pond and forested area." Forested area should be more descriptive as the eastern portion and parts of the southern portions of the property have the potential to provide vagrant stormwater drainage,dependent upon the volume and velocity of the stormwater event, otherwise,stormwater will sheet over these areas. If the "drainage area................and forested area."remains as written,then the Outfall SWOO1 current descriptive of forested area should be far more descriptive as outlined in Section a.above,as the forested area, north of the large retention pond associated with SW001,is actually a stormwater sheeting area. It is believed NC DEMLR reviewed these and other comments which were submitted on May 3, 2023, as typo errors were found later corrected. However, having heard no response to the main issue at hand of stormwater egress from the property and subsequently receiving an Individual NPDES Permit NCS 000566 to discharge stormwater from the property,The Lester Group—Fortress Wood Products, LLC, and NC DEMLR— Permit Rescission —Fortress Wood Products, LLC October 11, 2023 Page 3 of 3 Environmental Solutions and Strategies, LLC respectively request that personnel from NC DEMLR provide assistance, with this rescission request in determining if and where stormwater egresses the property proper. Si avi d ox President & CEO Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville,Virginia 24115 dmaddox(&com cast.net (email) 276-806-0178(telephone) 276-632-6137 (fax) C: ESz Files The Lester Group- Fortress Wood Products—High Point stormwater Files Exhibit A2 Supplemental Information ' EPA Form 1 Section M -Aerial reap with Property Lines 3874 Bethel Drive Extension High Point,North Carolina 27260 I Jlff jrr fe). '� - 4 • �.S-� , � y 1' -ice ' . � I � `E � � {!g'.71 i i-� �'� - ij■- t`x tP � - -11 w��., • W�'b.peg�w�r i' i+�wr � ��iF 1 'k�' "'�� 1 }by 1 '2 r X• � '.ry+.'� •'!�', / . � '' 1, Y �� t �•, 4 F° ii _.�..,r blt '"�x''y�u'�. ti ,1c' �. � �a.+'�;r:3• r _ .. - ,_ .+��.yll sW.:1.:ti ...s'c:,,L CZ blr Maps . . 3874 Bethel Dr Ext, High (point, NC 27260 My Notes Exhibit B l and B2ir Supplemental Information EPA Form 2F NPDES 70� i Section III—Site Drainage Maps On the go?Use m,bingxom to find maps, X 29 directior s,businesses,and more 2 6Kaso apace �. , r a a -wo 'b � ' s _ s iiVd . •va ts'�� - 29 ,4vaila 15 c1 6y[] a wio1A �:►.:� L4� a.+2 t4ratasa Do arsia. -8" e Bird's eye view maps can't be printed, so another map view has been substituted. http://www bing.com/maps/print.aspx?mkt=en-us&z=l7&s=b&cp=35914103,-80.04484... 11/27/2012 Maps 3874 Beffiel Dr Ext, High Point, PAC 27260 y Notes Exhibit D W �. Supplemental Information ; c f EPA Form 2F NPDES Large Aerial Lower Detention " Pond and Location Outfall 001 6YG:ns, Nif iresses,and more t•. k { aI i �3 Bird's eye view maps can't be printed, so another map view has been substituted. http://-vw,a.bing.com/maps/print.aspx?mkt=en-us&z=19.6')08673 09455436&s=b&cp=35... 1 1/27/2012