NCS000122_Staff Report_20190715

NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000122
General Timber, Inc
Sanford, NC
Facility Activities and Process:
• SIC Code: 2491— Wood Preserving. The facility produces fence posts. Raw wood and chip/mill
are formed into posts, which are treated and then stored in covered storage for drying. The
product is then stored for delivery. The facility uses CCA and creosote in the process. Chipping
operations onsite. The treated wood is temporarily sheltered.
• The facility discharges into Georges Creek, a class C stream in the Cape Fear River Basin.
Monitoring Information:
• General Timber previously had O'Brien & Gere overseeing permit requirements. Switched to
Hunt Environmental Associates in 2015. There are no monitoring reports present in the Central
Office paper file. The facility does not have consistent copies of monitoring reports before Hunt
Environmental Associates took over in 2015. There is a 5-year gap between 200 and 2005 and
gaps between 2005-2009, and 2010-2014.
• Outfall 001: Monitoring data shows consistent exceedances of the Copper benchmark of 0.007.
There were exceedances of TSS prior to 2015. There were 3 benchmark exceedances of pH in
2009 and 2010. Because of the Copper exceedances, Copper is not subject to a Tier Response. It
is written into the permit that the facility is responsible for installing a Copper Removal BMP and
continue to research and improve the site to reduce copper in monitoring data. Several events
after 2015 are labelled as "No Flow." However, the events that are labeled as "No Flow" had the
same amount of rainfall as monitoring events that produced monitoring data in previous years.
• Outfall 003: Monitoring data shows several exceedances of the Copper benchmark as well as
TSS. Stating in 2015, all monitoring events were recorded as "No Flow." Jordan Davis, with Hunt
Environmental, stated that, "In 2016, the CAMU and topography up -gradient of the outfall has
been altered and all flow hits a small basin up -gradient and the stormwater typically infiltrates
downwards into the soils a that, never reaching outfall 003.
• Outfall 002: There is limited data available for Outfall 002. There were no exceedances in 1999
and 2005. No flow in 2009 and 2019. Jordan Davis stated, "General Timber utilizes the area up -
gradient of the outfall for debarking/wood shavings storage which has altered natural
stormwater flow away from the outfall." It was also recorded that a topographic change at the
location contributes to it no longer being a discharge area.
Changes to the permit:
• In 2008, the company planned to phase out CCA treatment for a newer, more environmental
treatment, like C2. Chromium and arsenic were removed from the permit; however, the facility
did not transition.
• The facility has not sampled for chromium or arsenic since at least 2009.
• Amy Risen, with DWM — Haz Waste, counseled that we add in chromium III, chromium IV, and
PAH's (PAH to cover creosote treatment).

• Creosote is a parameter, but I have also added benzo(a)pyrene. I have attached information
about the PAH's in creosote.
• During the site inspection, a new outfall was discovered in the area where Outfall 002 previously
existed. —The inspection report is attached.
Surface Water Information:
• Georges Creek is listed as an impaired water experiencing problems with benthos.
• There is no TMDL for Georges Creek.
Discussions with the Facility:
• Contact was made with the facility over phone and email was made on 4/11/2019 and
monitoring data was received from Hunt Environmental on 4/30/2019.
Regional Office Information:
Sent to Regional Office Contact, Thad Valentine, on 4/15/2019.

Detailed Analysis of Polycyclic Aromatic Hydrocarbons (PAHs) in Creosote Oil on Rxi®-PAH
Peaks
Peaks
1. Benzo[ghi]fluoranthene
13. Dibenzo(a,j)anthracene
2. Benzo[c]phenanthrene
14. Dibenz [a,c]a nth racene
3. Benz[a]anthracene
15. Indeno[1,2,3-cd]pyrene
4. Triphenylene
16. Dibenz[a,h]anthracene
5. Chrysene
17. Benzo[b]chrysene
6. Benzo[b]fluoranthene
18. Picene
7. Benzo[k]fluoranthene
19. Benzo[ghi]perylene
8. Benzo[j]fluoranthene
20. Anthanthrene
9. Benzo(a)fluoranthene
21. Dibenzo[a,[]pyrene
10. Benzo[e]pyrene
22. Dibenzo[a,e]pyrene
11. Benzo[a]pyrene
23. Coronene
12. Perylene
24. Dibenzo[a,i]pyrene
25. Dibenzo[a,h]pyrene
5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 45.00 50.00 55.00 60.00 65.00 70.00
Time (min)
GC_EV1391
Column
Rxi@-PAH, 60 m, 0.25 mm ID, 0.10 pm (cat.# 49317)
Sample
Creosote oil standard (cat.# 31838)
Diluent:
Dichloromethane
Conc.:
50,000 pg/mL
Injection
Inj. Vol.:
1 pL split (split ratio 40:1)
Liner:
Premium 4 mm Precision liner w)wool (cat.# 23305.5)
Inj. Temp.:
275 °C
Split Vent
Flow Rate:
78 mL/min
Oven
Oven Temp.:
40 °C (hold 1.6 min) to 210 °C at 24 °C)min to 295 °C at 1.9 °C/min
to 350 °C at 3.7 °C/min (hold 6 min)
Carrier Gas
He, constant flow
Flow Rate:
1.95 mL)min
Detector
MS
Mode:
Scan
Scan Program:
Start Time
Scan Range
Scan Rate
Group (min)
(amu)
(scans/sec)
1 3.4
35-450
3.5
2 25
35-450
1.8
Transfer Line
Temp.:
330 °C
Analyzer Type:
Quadrupole
Source Type:
Extractor
Extractor Lens:
9mm ID
Source Temp.:
350 °C
Quad Temp.:
200 °C
Electron Energy:
70 eV
Solvent Delay
Time:
3.4 min
Instrument
Agilent 7890B GC & 5977A MSD
Restek Corporation 110 Benner Circle Bellefonte, PA 16823
1-814-353-1300 • 1-800-356-1688 • Fax:[phone] • www.restek.com