NCG140416_SW NOV GOBBLE CONCRETE_20170717

Energy, Mineral &
Land Resources
ENVIRONMENTAL OUALITV
July 17, 2017
CERTIFIED MAIL 07015 0640 0005 8164 4320
RETURN RECEIPT REQUESTED
Ronald Gobble
Gobble Concrete, Inc.
202 Leonard Road
Lexington, NC 27295
Subject: NOTICE OF VIOLATION
NOV-2017-PC-0475
Permit No. NCG 140416
Gobble Concrete, Inc.
Davidson County
Dear Mr. Gobble:
ROY COOPER
Governor
MICHAEL S. REGAN
sec'MM7
TRACY DAVIS
Director
On June 23, 2017, Jack Kitchens of the North Carolina Department of Environmental Quality
conducted a multimedia inspection of the Gobble Concrete facility located at 202 Leonard Road
in Lexington. Multimedia inspectors are required to conduct their inspections and report any
perceived deficiencies to the division responsible for maintaining permits in that specific area so
that determination can be made as to how to proceed. This facility is covered under General
Permit No. NCG 140101 which allows the discharge of stormwater point source discharges
associated with activities classified as Ready Mixed Concrete and like activities to the surface
waters of North Carolina
Compliance History:
This facility received a Notice of Deficiency (NOD) on July 27, 2016 following deficiencies
discovered during a multimedia inspection and subsequent follow-up. At that time the facility
had not developed and was not maintaining a Stormwater Pollution Prevention Plan (SPPP) and
was not conducting any qualitative or analytical monitoring. Since receiving the NOD, the
facility has developed an SPPP, has provided training and has begun qualitative and analytical
monitoring. The facility has missed one qualitative monitoring event since the last inspection in
July 2016. Analytical monitoring has been performed for TSS but required pH parameter has not
been analyzed in any sampling event.
StateofNIorth Carolina 1 Environmental Quality 1 Energy, Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill". Sultr3OO I Winston-Salem,NC 27103
336 776 9800

Gobble has made significant improvements since July of 2016 but the following observations
and violations were noted during NCDEQ's inspection and subsequent file review:
1. Stormwater Discharge - Qualitative Monitoring:
General Permit NCG 140000, Part IV Section C requires qualitative monitoring be
conducted twice per year following the established guidelines. It appears that one
required monitoring event has been missed since the facility received NOV in July of
2016.
2. Stormwater Discharge - Analytical Monitoring:
General Permit NCG 140000, Part IV Section A requires the facility to conduct analytical
monitoring twice annually at each of the facilities stormwater outfalls. Since the NOD
was issued in July of 2016, this facility has begun to provide analytical monitoring for
Total Suspended Solids (TSS) as required but, has not been monitoring for the required
pH parameter. TSS and pH are both required to be collected and tested semi-annually
within the schedule listed in the permit.
Reauired Response
Accordingly, you are directed to respond to this letter in writing within 30 calendar days of
receipt of this Notice. Your response should outline how the violations will be addressed and
should be sent to this office at the letterhead address and include the following:
1. Provide Qualitative Monitoring of Stormwater Outfalls twice annually. Keep records in
the SPPP binder.
2. Provide Analytical Monitoring of Stormwater Outfalls per permit requirements defined in
Part IV, Section A. TSS and pH are required parameters. Keep records in SPPP and
maintain for five (5) year minimum.
Thank you for your attention to this matter. This office may consider a recommendation for
enforcement to the Director of the DEMLR (Division of Energy, Minerals, & Land Resources)
regarding these issues and any future/continued violations that may be encountered. 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.
State of North Carolina 1 Environmental Quality 1 Energy, Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road. Suite 3001 Winston-Salem. NC 27103
336 776 9800

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 Glen White at [phone].
Sincerely,
o-�
Matthew E. Gantt, P.E. '
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
cc: DEMLR—WSRO
(Lisa Edwards, P.E.) DAQ WSRO
(Bethany Georgoulias) DEMLR Stormwater Permitting Unit — Raleigh
State oiNorth Carohna I Environmental Quality 1 Lnergy, Mineral and Land Resources
Winstor-Salern Regional Office 1 450 Hanes Mill Road Sulu 3001 Winston-Salem. NC 27103
336 776 9800

Permit: NCG140416 Owner• Facility: Gobble Concrete Inc
Inspection Date: 00/23/2017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yea No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0 ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
N ❑ ❑ ❑
# 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: Mr. Garrison has implemented the SPPP since the previous inspection on Julv 13. 2016. The
Responsible Party was designated and a signature was included. The facility has conducted
employee training since previous inspection. A document is maintained in the SPPP file is used.
to track employee training. Mr. Garrison and Mr. Andy Middleton are the only employees with
responsibilities of spill response, preventative maintenance, or operations that have potentential
to contaminate stormwater runoff. Mr. Garrison was instructed to maintain records of annual
training, which includes a plan review and/or update.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 1-10 ❑ ❑
Comment: Mr. Garrison documented one qualitative monitoring event since July 13, 2016. The qualitative
monitorina was in conjunction with an Analytical Monitoring event on August 19, 2016. It appears
that the facility has missed one semi-annually oualitative monitoring since the previous
inspection in July 2016. The semi-annual monitoring schedule outlined in the permit states that
one event should occur between July 1 and December 31. The second semi-annual monitoring
event would happen between January 1 and June 30.
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? ❑ 1:10 ❑
Page: 3

permit: NCG140416
Inspection Date: 06/23/2017
Comment:
Owner - Facility: Gobble Concrete Inc
Inspection Type: Compliance Evaluation
Reason for Visit: Routine
6/19/2017 - results pending. TSS results have been below benchmark values. Mr. Garrison was
reminded that minimum of 60 days must separate each monitoring event and that samples
should be analyzed for PH as well as TSS. Rainfall data is collected but the event duration has
not been recorded.
Permit and Outfalls Yea No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 110 ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ M ❑
Comment: The certificate of coverage (COC) available for review was dated May 31, 2016. The most
recent COC was not available for review at the time of the inspection. The certificate of
Coverage for the facility expires June 30, 2017. Mr. Garrison was reminded that renew coverage
Prior to the expiration date.
Page: 4

Compliance Inspection Report
Permit: NGG140416 Effective: 07/01/16 Expiration: 06/30/17 Owner: Gobble Concrete Inc
SOC: Effective: Expiration: Facility: Gobble Concrete Inc
County: Davidson 202 Leonard Rd
.Region: Winston-Salem
Lexington NC 27295
Contact Person: Chris Garrison Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/23/2017
Primary Inspector: Jack Kitchen
Secondary Inspector(s):
Certification:
Phone:
EntryTime: 10:15AM Exlt Tlme: 11:50AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Ready Mix Concrete Stonnwater/Wastewater Discharge CCC
Facility Status: ❑ Compliant N Not Compliant
Question Areas:
0 Storm water
(See attachment summary)
Page: 1

Permit: NCG140416 Omer -Facility; Gobble Concrete Inc
Inspection Date: 06/23/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On June 23, 2017, Jack Kitchen, Compliance Inspector, with the North Carolina Department of Environmental Quality,
conducted an announced. Multimedia Compliance Inspection at Gobble Concrete Company, Inc. The inspector met with
Chris Garrison, Vice President and plant operator, who provided the inspector access to the facility's equipment and
available records. Gobble Concrete was in operation on the day of the inspection.
The site drains to the Northeast section of the property. Ouffall #1 is identified in the NO1 as a reinforced concrete pipe. Mr.
Garrison showed Mr. Kitchen Outfall #1, which appeared of be an area covered in vegetation and brush. Mr. Garrison stated
that at the bottom of the ditch is a concrete culvert that leads stormwater off the property and under the adjacent railway.
The ditch is overgrown and not easily accessible. Mr. Kitchen observed the ditch in the area of Outfall #1 and did not notice
any evidence of ongoing erosion or recent discharges. According to previous inspection observations, the ditch would drain
into an unnamed tributary to Abbotts Creek. Mr. Garrison performs monitoring and sampling at a location prior to the ditch
and after the settling basin.
The concrete mixing trucks are rinsed on the loading pad with water provided by Davidson County. The truck wash and
irrigation runoff water drains to a holding basin constructed with gravel berms.
The mixing truck cleanout sedimentation basin was observed. The area is completely bermed at the far north end of the _
property. The dikes appeared to be constructed with dirt. At the time of the inspection, at least one foot of freeboard was
observed in the cleanout basin.
Admixtures used in the production of concrete are stored in ASTs and inside an enclosed shipping container. The loading
door is elevated and leaks or spills would collect at the end of the container. A single walled 12,000 -gallon diesel fuel above
ground storage tank (AST) was installed in November 2016 and replaced an existing 1,000 -gallon tank. The tank was
installed with concrete spill containment. The spill containment appeared to be adequately sized and in good condition. Mr.
Kitchen recommended that the drain valve be locked to ensure that accidental releases do not occur.
Based on observations documented by the inspector during the June 23, 2017 Multimedia inspection, it is recommended
that facility's compliance status be reviewed by DEMLR's Stormwater Program and DWR's wastewater Program to
determine if monitoring violations have occurred. A follow up inspection by DEMLR or DWR staff is recommended.
Page: 2