WT003078_Inspection_20220829

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
BRIAN WRENN
Acting Director
Annie R. Justice Heirs
Attn: Holbert Justice
3005 Northwoods Drive
Jacksonville, NC 28540
NORTH CAROLINA
Environmental Quality
August 29, 2022
Subject: Follow Up to Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG070000
No Certificate of Coverage WT003078
NOV#: NOV-2021-PC-0178
Facility: Justice Concrete Recycling
Onslow County
Dear Mr. Justice:
On August 16, 2022, Brian Lambe from the Wilmington Regional Office of the Division of Energy,
Mineral, and Land Resources (DEMLR), conducted a compliance evaluation inspection of Justice
Concrete Recycling located on 126 Charles Creek Road, Sneads Ferry, Onslow County, North Carolina.
The site drains to an unnamed tributary of Charles Creek, classified as SA, HQW, in the White Oak River
Basin.
The response from Wasiela Consulting PLLC outlines a deadline extension from the NOV dated August
17, 2021 to July 18, 2022. The response included compliance actions:
• Develop a site plan including property boundaries, structures, and topography.
Currently being developed by others and scheduled for deliverables February 1,
2022.
• Meet with Mr. Justice and perform a site inspection in early February to identify
current industrial activities, proposed continuing industrial activities and permits
needed to continue operations.
• Develop a site "clean-up" plan to remove or manage potential sources of storm
water pollution.
• Develop operations plans in accordance with permitting conditions as deemed
necessary by permitting agencies.
• Evaluate the need for Erosion & Sedimentation Control permitting through
NCDEQ-DEMLR, Land Quality Section.
• Develop a reclamation plan for the previously mined area in the northwest corner
of the property.
• Procure necessary permits or permit coverage for ongoing site activities.
While there has been clean up occurring on site, there is no formalized reporting to this office. A permit
has not been applied for. The NPDES permitting would require documentation of actions taken in the
form of the Stormwater Pollution Prevention Plan (SPPP). The site has been conducting remediation
without benefit of the permit coverage nor a SPPP. The SPPP is designed to act as a guide and method of
documentation for all actions taken in response to stormwater pollution.
D E Q_�
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405
NORTH CAHOLIN�
°°w'° M W En"'°'. tal D' ,i /
910.796.7215

Justice Concrete Recycling
Page 2 of 3
The following observations and violations were noted during the DEMLR inspection and file review:
1. Concrete is collected and crushed onsite. Discharges associated with this activity need
coverage under NPDES NCG070000 Stone, Clay, and Glass or NCG130000 Non Metal Waste.
2. Construction waste material is collected onsite. Discharges associated with construction
waste product needs permit coverage under NPDES NCG120000 Landfills.
Marine construction waste and product is collected onsite. Several derelict boats are
stored onsite. This may be considered for coverage under NPDES NCG120000 Landfills, but the
concentration of treated lumber may not fit into a general permit, necessitating an individual
permit.
4. A thorough evaluation of potential pollutants is needed. The site may need to apply for
an individual permit to cover all potential sources of pollutants.
5. The facility has a mine site in the rear of the property without a state mining permit and
is being dewatered into wetlands without a NPDES NCG020000 permit.
6. Erosion and sediment control permits may be applicable and need further
consideration. State stormwater permits may need to be acquired for the Built Upon Area (BUA)
constructed after 1988.
Required Response
You offered a deadline of July 18, 2022 per your response to the Notice of Violation. Your response is
still required and should be sent to this office at the letterhead address and include the following:
1. Apply for coverage under a NPDES Industrial Stormwater general or individual permit.
2. Apply for a permit under NC Sedimentation Control or Mining permit with associated
NCGO10000 or NCG020000 permit coverage.
3. Schedule of compliance with all aspects of the site being addressed.
a. Map
b. Narrative of operations of the facility
c. Identification of discharges of stormwater
d. Identification of possible pollutants
e. Best Management Practices to be used
f. Removal of pollutants
4. Show documentation of any actions associated with removal of potential pollutants.
Thank you for your attention to this matter. This office requires that the violations, as detailed above,
be abated immediately and properly resolved. Environmental damage and/or failure to secure proper
authorizations have been documented on the subject tract as stated above. Your efforts to undertake
activities to bring the subject site back into compliance is not an admission, rather it is an action that
must be taken in order to begin to resolve ongoing environmental issues.
Pursuant to G.S. 143-215.6A, these violations and any future violations are subject to a civil penalty
assessment of up to a maximum of $25,000.00 per day for each violation. Your above -mentioned
response to this correspondence, the degree and extent of harm to the environment and the duration
and gravity of the violation(s) will be considered in any civil penalty assessment process that may
occur. Should you have any questions regarding these matters, please contact Brian Lambe or me at
[phone].
Sincerely,

Justice Concrete Recycling
Page 3 of 3
Brian Lambe
Environmental Specialist II
Land Quality Section
Attachments: BIMS Inspection Checklist
cc: Central Files —LF
WiRO Files — Land Quality
Brittany Carson, DEMLR (email)
Ray Williams, DWM (email)