NCG140266_Company Response to NOV 15Jul2019_20190722

DUNCKLEE ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
&Q_ DT 7�Tu A �( CARY, NORTH CAROLINA 27518
lJ j�l l ll' M OFFICE: [phone]
W W W.DUNCKLEEDUNHAM.COM
July 15, 2019
Mr. Tony Victor
Environmental Specialist
Town of Morrisville
100 Town Hall Drive
Morrisville, NC 27560
Reference: Response to Notice of Violation #05-2019
Thomas Concrete of Carolina, Inc.
Morrisville Batch Plant, Morrisville, Wake County, North Carolina
Dear Mr. Victor:
Duncklee & Dunham, P.C. (Duncklee & Dunham), on behalf of Thomas Concrete of Carolina, Inc.
(Thomas Concrete), submits this letter in response to the Notice of Violation (NOV) issued by the Town of
Morrisville (Town) on July 1, 2019, for the above -referenced site. This letter summarizes the findings of a
recent inspection conducted by the Town and corrective actions planned by Thomas Concrete to address
the findings.
Findings
Town staff conducted a site visit at Thomas Concrete's Morrisville Batch Plant at 220 International Drive,
Morrisville, North Carolina on June 27, 2019 for the purpose of monitoring dry weather flow from the
site's stormwater outfalls. During the visit, Town staff observed concrete residue at Outfall I0_1074 and
foam in a nearby stream on the east side of the concrete plant, and additional deposition of concrete residue
in an area south of Outfall I0_1074 . Based on these observations, the Town issued a Notice of Violation
to Thomas Concrete, dated July 1, 2019, for an Illicit Discharge of wastewater from the facility (attached).
The NOV directed Thomas Concrete to respond in writing with a description of corrective actions and
preventative measures to include:
1. a description of cleanup measures Thomas Concrete will perform to the clean the areas impacted
by the illicit discharge;
2. a plan of action for preventing future illicit discharges from entering the storm drain system and
the stream; and
3. a plan of action to concrete plant staff about proper measures to prevent concrete residue from
entering the stormwater conveyance system.
MAILING ADDRESS - POST OFFICE BOX 639 - CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DEQ REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061

Response to NOV
Thomas Concrete of Carolina, Inc.
Morrisville, North Carolina
July 15, 2019
Page 2 of 3
2 Response
2.1 Written Description of Cleanup Measures
Thomas Concrete will remove concrete residue and foam impacted media (e.g. rip rap, soil) present in the
outfall and downstream impacted areas. Any rip rap removed from the outfall will be replaced. During
cleanup procedures, the plant will take measures to prevent wastewater discharge from Outfall I0_1074
including collection, temporary storage, and re -use of recycled wastewater at the facility and removal of
accumulated solids from the settling pits on the north end of the plant to increase the site's wastewater
holding capacity.
2.2 Plan of Action for Preventing Future Illicit Discharges
Section 7.6.1.A.20. of the Town of Morrisville's Unified Development Ordinance states that "non-
stormwater discharges for which a valid NPDES discharge permit has been approved and issued by the
State of North Carolina" are allowed "provided that they do not significantly impact water quality." The
facility currently operates under NPDES Permit General Permit NCG140000 (Certificate of Coverage
NCG140266, attached) issued by the North Carolina Department of Environmental Quality. Process
wastewater discharges from vehicle and equipment cleaning, raw material stockpiles, and mixing drum
cleanout are authorized under this permit, and are subject to effluent limits for pH, total suspended solids,
and oil & grease. Therefore, the facility will not discontinue the discharge of wastewater through the
outfalls; however, they will improve measures to comply with the permit effluent requirements.
Per Thomas Concrete's request, Duncklee & Dunham personnel will meet with plant staff to review the
wastewater permit effluent limits and identify measures to prevent wastewater discharges that would violate
the permit effluent limits.
2.3 Plan of Action to Prevent Concrete Residue from Entering Stormwater Conveyance System
Pursuant to the stormwater/wastewater permit, Duncklee & Dunham prepared a Stormwater Pollution
Prevention Plan (SWPPP) for the site that details stormwater control measures and best management
practices to reduce pollutant levels in stormwater and wastewater discharges from the facility. These
practices include structural controls to treat stormwater/wastewater discharges, good housekeeping
measures to reduce potential contaminant sources, and implementation of inspection and training schedules
to identify and minimize pollutant sources.
Per Thomas Concrete's request, Duncklee & Dunham will meet with facility staff to review the site's
SWPPP and enhance their awareness and understanding of the contents of the Plan. In addition, we will
evaluate with facility staff the effectiveness of the current stormwater BMPs listed in the Plan in preventing
pollutants (including concrete residue) from entering the stormwater conveyance system, and
identify/discuss additional measures that may be needed (e.g. additional wastewater treatment equipment,
enhancements to the good housekeeping program, etc.) to reduce pollutants in stormwater/wastewater
discharges and prevent impacts to receiving surface waters. We will update the SWPPP accordingly
following this review/evaluation.
We trust that the corrective actions discussed in this letter will adequately address the issues identified
during the inspection and prevent further adverse impacts from stormwater/wastewater discharges to
L> DUNCKLEE & DUNHAM, P.C.

Response to NOV
Thomas Concrete of Carolina, Inc.
Morrisville, North Carolina
July 15, 2019
Page 3 of 3
downstream surface waters. Please contact Lily Walker at Duncklee & Dunham at [phone], ext.
105 or [e-mail] or Justin Hartley at Thomas Concrete at [phone] or
[e-mail] if you have any questions or require additional information.
Sincerely,
Duncklee & Dunham, P.C.
G
Lily Walker
Staff Engineer
Senior Peer Review:
6a4 oo/' ILI" ,
Andrew Rodak, P.E.
Director of Engineering
Cc: Justin Hartley, Thomas Concrete
Sherwood Turner, Thomas Concrete
Attachments: Notice Violation — NOV # 05-2019
NPDES Stormwater Permit Coverage Renewal COC #NCG140266
PAThomas Concrete\ECAP - 201909\Inspections\2019\Reg Agencies\NW NOV 7_1_19\Response to NOV 7-1-19-19449.doc
DUNCKLEE & DUNHAM, P.C.

Morrisville
Live connected. Live well.
ioo Town Hall Drive
Morrisville, NC 2756o
P: 919.463.62oo
F: 919.481.2907
tow nofinorrisvi lle.org
July 1, 2019
CERTIFIED MAIL # 70042890000054616275
RETURN RECEIPT REQUESTED
Thomas Concrete of Carolina, Inc
2500 Cumberland Pkwy SE, STE 200
Atlanta, GA 30339-3922
Subject: NOTICE VIOLATION — NOV # 05-2019 Lat/Long: 35.838450/-78.821649
Illicit Discharge
Thomas Concrete of Carolina, Inc, 220 International Dr., Morrisville, NC 2756o
On 6/27/19 at approximately 11:42 am, Town of Morrisville Staff observed concrete residue at Outfall
I0_1o74 while conducting routine dry weather flow monitoring of outfalls. The concrete residue was
observed directly at the outfall and running along a path through the wooded area and down and into
the stream on the east side of the concrete plant. The water of the stream had a foam on the surface
for approximately too feet. The foam was in a pool of the stream and was hindered from proceeding
further down stream by a rock riffle structure and the foam was not observed on the surface beyond
this point. It was observed at the time that no water or concrete residue was flowing from the outfall
at the time of discovery.
Also observed further to the south of Outfall I0_1o74 was an area where concrete residue was
deposited by what appeared to be activity from above the slope. It appeared that concrete slurry was
being pushed over the embankment and down the slope and being deposited on the slope and at the
bottom of the slope. At the bottom of the slope there was an area approximately 20'x20' where
concrete residue had deposited to a depth of several inches.
Town Staff met with the Plant Manager and walked the parking lot. It was observed that Curb Inlets
CI_164 & CI_165 had straw bales beside them. There was significant concrete slurry on the paved
area and there was a path from the concrete slurry on the paved area to the curb inlets during rain
events that lead to Outfall I0_1074. At the plant catchment basins where trucks rinse, it was observed
that there were areas where the slurry has been pushed over the sides of the east slope.
Town Staff informed the Plant Manager that a Notice of Violation would be issued to the Property
Owner and that the State of North Carolina would also be contacted as the concrete residue had
impacted the stream running along the east side of the concrete plant.

As a result of the site inspection, the following violations, detailed below, are noted:
Item I.
ILLICIT DISCHARGE
This violation, covered under Article 7.6 of the Town of Morrisville's Unified Development
Ordinance (UDO) associated with our National Pollutant Discharge Elimination System
(NPDES) Phase II permit (NCSo00465). The purpose of these rules is to protect water quality
in the Neuse and Cape Fear River Basins.
Required Response:
You are directed to respond to this letter in writing within 15 days of receipt.
Submit a written description of cleanup measures Thomas Concrete of Carolina, Inc
i. will perform to clean the areas impacted by the illicit discharge. The plan should include
measures to avoid any active or residual illicit discharge from impacting the stormwater
conveyance and the stream.
2. Provide a plan of action for preventing future illicit discharges entering the storm drain system
and the stream.
3. Provide a plan of action to concrete plant staff about proper measures to prevent concrete
residue from entering the storm water conveyance and the stream.
Submit Required Items To:
Tony Victor
Environmental Specialist
Town of Morrisville
10o Town Hall Drive
Morrisville, NC 27560
Thank you for your attention to this matter. This office requires that the violations, as
detailed above, be repaired within the allocated timeframe. These violations and
any future violations are subject to a civil penalty assessment of up to $25,000.00
per day for each violation. Should you have any questions regarding these matters, please
contact Tony Victor at 919-463-6172.
Sincerely,
t
oshua Baird, PE, CFM
Stormwater Engineering Manager (Acting Town Engineer)
cc: File
Tony Victor, Environmental Specialist

Energy, Mineral &
Land Resources
ENVIRONMENTAL OUALITV
August 1, 2017
Thomas Concrete Of Carolina Inc
Attn: Justin Hartley
PO Box 12544
Raleigh, NC 27605
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Dlrector
Subject: NPDES Stormwater Permit Coverage Renewal COC #NCG140266
Dear Permittee:
For coverage under Stormwater General Permit NCG140000, the Division of Energy,
Mineral, and Land Resources (DEMLR) is forwarding herewith the reissued Certificate of
Coverage (COC). This permit is reissued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between the state of North
Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as
subsequently amended.) A new Certificate of Coverage (COC) is included with this
letter.
You must print a copy of the new NCG140000 General Permit from our website here:
htt a.V (e .nc.gov/about/divisiolis erlergy ntinei-al-la11d-resources/energy-niiiierzil-lanc:l-
mits/stormwater-permits/npdes-industrial-sw. In addition to the full permit, the 2017
print package on the website includes revised Discharge Monitoring Report (DMR) forms,
Annual Discharge Monitoring Report forms, and Qualitative Monitoring Report Forms.
The General Permit authorizes discharges of stormwater and wastewater (if applicable),
and it specifies your obligations with respect to discharge controls, management,
monitoring, and record keeping. Please review the new permit to familiarize yourself with
all changes in the reissued permit. Significant changes to the General Permit are
outlined in the Technical Bulletin, which is also available on the website above. Your
facility has six months from receipt of the permit to update your Stormwater Pollution
Prevention Plan (SPPP) to reflect any new permit requirements.
--''-Nothing Compares
SState of North Carolina I Environmental Quality I Energy. Mineral and Land Resources
512 N. Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612
919 707 9200

How does the new General Permit affect Tier Status?
The first sample period of your permit begins August 1, 2017. Tier 3 actions in Part IV of
your permit are triggered by benchmark exceedances on four occasions beginning on the
effective date of this permit and do not count prior exceedances. Likewise, Tier 2 actions
are triggered by two consecutive benchmark exceedances beginning on the effective date
of this permit and do not count prior exceedances. Howeverif your facility is already in
Tier 2 (monitoring stormwater discharges monthly) or Tier 3, you must continue monthly
monitoring until relieved through conditions of the permit or by DEMLR staff approval.
When does electronic DMR reporting start?
We are setting up our database with final permit parameters and the outfalls that
permittees submitted on-line. All NCG14 Permittees will receive notification when our
eDMR system is ready for these permittees to register and begin reporting
monitoring data electronically. If you have any questions about the status, please
contact Bethany Georgoulias at [phone] or Robert Patterson at [phone]. If
you did not submit outfall information already, we have included a form for you to return
to us. (Note: NO FORM IS ATTACHED if we already have your outfall information.)
Your coverage under the General Permit is transferable only through the specific action of
DEMLR. This permit does not affect the legal requirements to obtain other permits which
may be required by the N.C. Department of Environmental Quality (DEQ), nor does it
relieve the permittee from responsibility for compliance with any other applicable federal,
state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact the DEMLR
Stormwater Permitting Program at [phone].
cc: Stormwater Program files
Sincerely,
for Tracy E. Davis, P.E., C.P.M.
Nothing Compares_
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 11612 Mall Service Center I Raleigh, North Carolina 27699-1612
919 707 9200

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
STORMWATER AND WASTEWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Thomas Concrete Of Carolina Inc
is hereby authorized to operate approved wastewater treatment system(s) and discharge
stormwater and/or wastewater, as approved in the original permit/application or
subsequent permit modification, from a facility located at:
Thomas Concrete Of Carolina Inc - Moorisville
220 International Dr
Morrisville
Wake County
to receiving waters designated as Crabtree Creek, class QNSW waters in the Neuse River
Basin, in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, I1, III, IV, and V of General Permit No. NCG140000 as
attached.
This Certificate of Coverage (COC) shall become effective August 1, 2017.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 1, 2017.
T6g (/K,foff
for Tracy E. Davis, P.E., CPM
Director, Division of Energy, Mineral, and Land Resources
By the Authority of the Environmental Management Commission