NCS000122_Email_20190502

Garcia, Lauren V
From: [e-mail]
Sent: Thursday, May 02, 2019 1:46 PM
To: Garcia, Lauren V
Cc: Morman, Alaina; [e-mail]; 'Greg Williams'
Subject: RE: [External] Re: NCS000122 NPDES Stormwater Permit Renewal
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[e-mail]
Mrs. Garcia,
General Timber has in the past couple years tried to centralize the storage of treated wood products to the stacking area
located immediately at the front entrance, to control run-off and leaching from these products. We are currently
working on a plan to address SWMU 27, which is basically the entire area supplying stormwater run-off to Outfall 001.
Part of which includes a plan to cover the treated material and address any soil contamination as necessary. Below are
the background soil values as measured in recent reporting for reference.
Background
Samples
Parameters
Totals mg/kg
Arsenic
Chromium
Copper
Average
9.60
18.7
10.6
Maximum
42.6
58.4
26.5
Minimum
1.37
7.20
3.35
Also, yes mostly all stormwater overland flow leaves through outfall 001.
Without seeing the new permit, one comment I know we would have is a request to increase the copper limit given that
copper is naturally occurring in the native soils.
Please let us know a good day to meet on -site.
Respectfully,
Jordan Davis
Environmental Scientist
Hunt En ♦ ironmental Associates
Email: heajcdavisggmail.com
Web: heaenviro.com
Phone: [phone]
Fax: [phone]
Office: 3330 Saddletree Road, Lumberton, NC
Mail Drop: Post Office Box 390
Lumberton, North Carolina 28359
1

From: Garcia, Lauren V <[e-mail]>
Sent: Wednesday, May 1, 2019 11:54 AM
To: Jordan Davis <[e-mail]>
Cc: Morman, Alaina <[e-mail]>
Subject: RE: [External] Re: NCS000122 NPDES Stormwater Permit Renewal
Hi Jordan,
While I can see how a trickle would be hard to take a sample from, this still counts as a stormwater discharge from the
site. I believe it is reflected in the limited data that TSS was reduced in 2015 and 2017, compared to previous years.
However, for these same two samples, copper still exceeded the benchmark value and was measured at an all time high
for the site in 2017. Just going by these two samples, it does not seem like the BMPs installed to combat TSS are linked
to Copper. Here it would be helpful to see any documentation of investigation into what produced the spike in Copper in
2017 or of maintenance and upkeep/improvements through site modifications to the Copper removal BMP that was
installed at Outfall 001.
With these topographical changes, is it safe to say that all stormwater that does not infiltrate into soil leave through
outfa I 1 001?
I agree and think a site meeting would be helpful to re-evaluate site modifications and Copper sampling requirements in
this next permit term.
Thanks,
Lauren
From: Jordan Davis <[e-mail]>
Sent: Wednesday, May 01, 2019 10:46 AM
To: Garcia, Lauren V <[e-mail]>
Cc: Cody Hunt <[e-mail]>; Greg Williams <[e-mail]>
Subject: [External] Re: NCS000122 NPDES Stormwater Permit Renewal
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1 [e-mail]
Mrs. Garcia,
Efforts have been taken to reduce the suspended solids at the outfalls through BMPs. Its our expectation that since the
metals are most likely mobilized through sediment transport that these BMPs should help with cooper exceedances.
Outfall 002: 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.
Outfall 003: 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 downward into the soils at that point, never reaching outfall 003.
Furthermore, according to the site manager Mr. Greg Williams in prior years when previous consultants attempted to
sample it was barely a trickle at the outfalls. Mr. Williams also stated that all previous samples were fairly turbid which
could contribute to the exceedances. Moving forward it may be best for us to conduct a site meeting prior to finalizing
the new permit, in order to identify the most representative areas for monitoring.
Thanks,

Jordan Davis
Environmental Scientist
Hunt Environmental Associates
Email: heajcdavis a gmail.com
Web: heaenviro.com
Phone:[phone]
Fax:[phone]
Office: 3330 Saddletree Road, Lumberton, NC
Mail Drop: Post Office Box 390
Lumberton, North Carolina 28359
On Wed, May 1, 2019 at 8:59 AM Garcia, Lauren V <[e-mail]> wrote:
Hi Jordan,
There is a section in the permit that excludes Copper from the increased monitoring requirements of Tier II at Outfall
001. Instead of monitoring records for this, as all previous years of data showed values of Copper above the
benchmark, are there any records of the facility investigating the source of Copper in the stormwater discharges from
the facility? Have there been any site modifications or stormwater controls implemented in order to reduce the Copper
in the stormwater discharges?
Has a copper removal BMP been installed at Outfall 001?
I see from your monitoring data that there is no flow listed for Outfall 003 from 2015-Present and only two monitoring
events have taken place at Outfall 001. Can you please explain why there has been this change when the site was
receiving the same amount of rainfall as previous years sampled?
Thanks,
Lauren
3

From: Garcia, Lauren V
Sent: Tuesday, April 30, 2019 5:02 PM
To: Jordan Davis <[e-mail]>
Subject: RE: [External] NPDES Stormwater Permit Renewal
Hi Jordan,
Thank you so much for sending this to me. I'm sorry it was so much work to find everything.
I do have a quick question, I see here that there were several benchmark exceedances of copper, pH, and TSS. The 2008
permit had a Tiered response section. Do you have any of the records or monitoring data available for the Tier events
that would have been triggered by these exceedances?
Thanks so much,
Lauren
From: Jordan Davis <[e-mail]>
Sent: Tuesday, April 30, 2019 4:49 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Cody Hunt <[e-mail]>
Subject: [External] NPDES Stormwater Permit Renewal
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Mrs. Garcia,
Sorry for the delay we needed to go through the print files on -site in order to locate previous monitoring data to 2015
(when we were hired by General Timber). Greg is currently reviewing the summary to make sure no changes need to be
made. There have been no operational changes since last permit issuance.
If you need any additional information please let me know.

Thanks,
Jordan Davis
Environmental Scientist
Hunt En ♦ ironmental Associates
Email: [e-mail]
Web: heaenviro.com
Phone:[phone]
Fax:[phone]
Office: 3330 Saddletree Road, Lumberton, NC
Mail Drop: Post Office Box 390
Lumberton, North Carolina 28359