NCG140232_COMPLETE FILE - HISTORICAL_20170724

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
IV 1 yo a 3a
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
YYYYMMDD

ROY COOPER
Govemor
MICHAEL S REGAN
Secretary
Environmental
Quality
July 24, 2017
KENNLFH WALGFRI F—CORPORAIL EHS MANAGER
CHANDLERCONCRH UPIFDMONr INC-CHIMNEYROCKRD PLANI 103
1006 A C14URCH S I RLI I
BURLINGTON, NC 27216
Subject Multimedia Compliance Inspection
CHANDLER CONCRFI I /PILDMONT INC - CHIMNEY
ROCK RD PLANT 103
COUNTY Guilford
Dear Permittee
Department of Environmental Quality staff from the Winston-Salem Regional Office conducted a
multimedia compliance inspection of Chandler Concrete/Piedmont Inc - Chimney Rock Rd Plant 103 on
July 3, 2017 for permits and programs administered by the following Divisions
Division of Air
Division of Energy,
Division of Water
Division of Waste
Quality
Mineral, and Land
Resources
Management
Resources
We appreciate your cooperation during the inspection and hope that you have enjoyed the benefit of our
initiative to provide a single inspector capable of handling multiple areas of environmental compliance at
your facility The results of each applicable inspection and any associated response actions or necessary
corrective measures are detailed in the inspection letters/reports attached to this transmittal sheet If a
Division report is not attached, you may assume compliance with that Division's rules and regulations at
the time of inspection
If you have any questions regarding this multimedia inspection, please contact Jack Kitchen at (919) 219-
0402 or Jack Kitchen@ncdenr gov Thank you for your cooperation
encl Air Quality Inspection Report
Stormwater Inspection Report
cc DAQ WSRO Files
DEMLR WSRO Files
DWR WSRO Files
DWM WSRO Files
Siatt of North Carolina I Environmental Quality
Winston Salem Regional Office 1 450 West Hanes Mill Road suite 300 1 Winston Salem North Carolina 27105 7407
336 776 9800 T 1 336 776 9797 F

NORTH CAROLINA DIVISION OF
AIR QUALITY
Inspection Report
Date 07/03/2017
Facility Data
Chandler Concrete/Piedmont, Inc - Chimney Rock Rd Plant 103
114 North Chimney Rock Road
Greensboro, NC 27409
Litt 36d 4 6816m Long 79d 55 0683m
SIC 3273 / Ready -Mixed Concrete
NAICS 32732 / Ready -Mix Concrete Manufacturing
Winston-Salem Regional Office
Chandler Concrete/Piedmont, Inc -
Chimney Rock Rd Plant 103
NC Facility ID 4100992
County/FIPS Guilford/081
Permit Data
Permit n/a
Issued n/a
Expires n/a
Classification Permit! Exempt
Permit Status Inactive
Current Permit Application(s) None
Contact Data
Program Applicability
SIP
Facility Contact
Authorized Contact
Technical Contact
William T Fisher
Kenneth Waegerle
Kenneth Waegerle
Plant Manager
Corporate EHS Manager
Corporate EHS Manager
[phone]
[phone]
[phone]
[phone] mobile
William fishtrachandlerconcrete com
Comments Multimedia Inspection
Compliance Data
Inspector's Signature
Inspection Date 07/03/2017
Inspector's Name Jack Kitchen
Operating Status Operating
Compliance Code Compliance -
Date of Signature July 12, 2017
RS
inspection
Action Code FCE
On -Site Inspection Result Compliance
I Total Actual emissions in TONS/YEAR I
TSP
S02
NOX
VOC
CO
PM10
* HAP
2012
0 1 100
---
---
---
---
00500
---
2008
0 1500
---
--
--
--
00700
--
Five Year Violation History None
Date Letter Type Rule Violated
Performed Stack Tests since last FCE None
Date Test Results Test Method(s)
* Hwhest HAP Emitted (in
Violation Resolution Date
Source(s) Tested

Emission Sources
Emission Emission Source Control
Source ID Description System lQ
Control System
I Description
One Truck -Mix Concrete Batch Plant (90 cubic yards per hour maximum capacity) consisting of
ES -I
Cement storage silo
CD -I
r
Bagfilter (1,490 square feet of filter area)
ES-2
Flyash storage silo
ES-3
Cemendfiyash weigh hopper
ES-4
Truck loadout operation
Insignificant Sources
Source Exemption I Source of TA Ps Source of Title V
Regulation J Pollutants
1-1 —one natural gas -fired hot water 2Q 0102(c)(2)(13)(n) Yes Yes
heater (0 825 million Btu per hour
maximum heat input capacity)
I-2 — concrete admixture tanks 2Q 0102(c)(1)(L)(xii) No Yes
(500-2,400 gallons capacity, range)
Introduction
On July 3, 2017, Mr Jack Kitchen, inspector with NCDEQ met with Ken Waegerle, Environmental, Health, and Safety
Manager and William T Fisher, Plant Manager, of Chandler Concrete/Piedmont, Inc - Chimney Rock Rd Plant 4103 for an
announced Multimedia compliance inspection Mr Kitchen previously inspected the facility on July 6, 2016 and the facility
appeared to be in compliance with Air Quality standards and regulations at the time of the inspection Plant 4103 is a truck
mix, concrete, batch plant The plant operating hours are flexible due to an inconsistent demand for concrete production
Currently, Mr Fisher works at Chandler's nearby Swmg Rd facility, Plant #102 Plant'4103 on Chimney Rock Rd is a
backup' facility that i5 remotely operated from the control room of Plant #102 on Swing Rd (BEAM contact information
was reviewed and updated Required safety equipment on this site includes safety shoes, hardhat, safety glasses, hearing
protection and a safety vest
Applicable Rezulations
The facility is subject to the following regulations Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D
0202, 2D 0515, 2D 0521, 2D 0535, 2D 0540, 2D 1806 and 2Q 0309 This facility is not subject to RMP requirements of
the 112(r) program since it does not use or store any of the regulated chemicals in quantities above the threshold levels in the
rule The facility is only subject to the General Duty requirements contained in the General Duty Clause
O ratin Status/Discussion
This facility is a truck mix concrete batch plant This facility utilizes a cement storage silo (ES-1) and flyash storage silo (ES-
2) located side by side Each silo auger feeds to a weigh hopper (ES-3) that discharges to the truck loadout (ES4) Emissions
from all of these sources are controlled by a baghouse, consisting of 1,490 square feet of bagfilter area (CD-1) The collected
dust from this bagfilters is recycled back into the fly ash silo The facility was observed during operation and was receiving
cement at the time that Mr Kitchen was on site All ducts appeared to be in good condition without visible holes or breaks
The exterior of the baghouse looked to be in good condition with no accumulation of dust or evidence of bagfilter failure
Aggregate and sand that is stored in piles on the property is loaded and conveyed into a weigh hopper The cement and flyash
are dispensed from silos into a weigh hopper The particulate emissions generated during loading the weigh hopper is
exhausted through the central collection bagfilters The dry contents of the hopper are discharged into a mixing truck During
truck loadout, emissions are suppressed by a shroud placed around the mi ong drum s input Particulate emissions generated
during truck loading is vented to bagfilter Water is added into the truck mix An electric hot water heater is used when

temperatures approach freezing Records reviewed at the facility denote that the plant produced 13,665 yds3 of concrete
during the calendar year 2016 Mixing trucks are washed in basin to prevent fugitive emissions leaving the property
Applicable Regulations
15A NCAC 2D 0515 - Particulate Control Requirement This condition sets the maximum allowable particulate
emissions using the following two equations
E = 4 10 * (P) 061 for P <= 30 tons/hr , or
E = 55 * (P) ° " - 40 for P >30 tonsthr
According to emission calculations performed during a permit review (R09) using the NCDENR Concrete Batch Plant
Emissions Calculator, the weigh hopper and fly ash silo both require a control device to achieve compliance with this rule
while the cement silo and loadout can comply uncontrolled The dust collector (CD-1) appeared to be properly installed and
sutficeently mamtained, therefore, compliance is expected
15A NCAC 2D 0521 - Visible Emissions Control Requirement This facility is limited to 20% opacity visible emissions
(VE) when averaged over a six -minute period On the day of the inspection, Mr Kitchen observed the plant while loading
mixing trucks and receiving cement to a storage silo Fly ash was received early in the day prior to the inspection No visible
emissions were observed and no accumulated cement or fly ash on the outside of the exhaust outlet of CD-1 Compliance was
observed at the time of the inspection
15A NCAC 2D 0535 — Th is regulation requires the permittee to notify the director of any excess emissions lasting longer
than four hours resulting from a malfunction, a breakdown of process or control equipment or any other abnormal conditions
Mr Fisher and Mr Waegerle stated no excess emissions lasting longer than four hours had occurred, therefore, indicating
compliance with 2D 0535 ,
15A NCAC 2D 0540 - Fugitive Dust Control Requirement According to the DAQ IBEAM database and facility file, no
i
complaints have been received regarding fugitive dust emissions at this facility Compliance with 2D 0540 is expected
15A NCAC 2D 1806 - Control and Prohibition o€ Odorous Emissions Requirements No objectionable odors were
detected during the approach to the facility or within the property boundaries The facility does not have any previous odor
complaints in the IBEAM database Compliance with 2D 1806 is expected
New Source Performance Standards (NSPS) & National Emission Standards for Hazardous Air Pollutants (NESHAP)
Mr KrtLhen did not observe emergency generators on site Mr Waegerle and Mr Fisher stated that the facility does not
utilize generators A small natural gas fired hot water heater is used to heat ,water during winter months Because the unit is
natural gas -Fred, it is not Subject to 40 CFR Part 63 Subpart JJJJJJ 'Phis facility does not appear to be subject to any NSPS
or NESHAP rules at the time of the inspection
Facility Wide Emissions
The facility wide actual emissions from the CY2012 emission inventory are located in the report header The facility
produced a total 13,665 cubic yards of concrete in CY2016
Source Tests
No stack testing or VE testing has ever been conducted at this facility
Compliance History
This facility has not been issued any Notices of Violation or Deficiency in the previous five years

Conclusion
Based on the mspector s observations and review of available records, this facility appeared to be operating in compliance
with Air Quality standards and regulations at the time of this inspection
4

Compliance Inspection Report
Permit NCG140232 Effective 07/01/16 Expiration 06/30/17 Owner Chandler Concrete/PledmontInc
SOC Effective Expiration Facility Central Concrete Co - Chimney Rock Road Pit #103
County Guilford 114 N Chimney Rock Rd
Region Winston-Salem
Greensboro NC 27409
Contact Person Kenneth E Waegerle Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC Certification Phone
Secondary ORC(s)
On -Site Representative(s)
Related Permits
Inspection Date 07/03/2017 Entry Time 02 OOPM Exit Time 03 30PM
Primary Inspector Jack Kitchen Phone [phone]
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Ready Mix Concrete StormwaterNVastewater Discharge COC
Facility Status Compliant Not Compliant
Question Areas
Storm Water
(See attachment summary)
Page 1

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
inspection Date 07/03/2017 Inspection Type Compliance Evaivation Reason for Visit Routine
Inspection Summary
On July 3 2017 Jack Kitchen Compliance Inspector with the North Carolina Department of Environmental Quality,
conducted a Multimedia Compliance Inspection at Chandler Concrete Company - Plant #103 The inspector met with Ken
Weagerle Environmental Health and Safety Manager and William Fisher Plant/Production Manager who provided the
inspector access to the facility s equipment and available records
Plant #103 is a remote location at 114 N Chimney Rock Rd in Greensboro and controlled by Swing Road Plant #102 No
employees are stationed on site Plant #103 operates as a backup for other Chandler batch plants predominantly for plant
#102 13 665 cubic yards of concrete were produced in 2016 and 3 115 cubic yards were produced through May 2017
Employee training is conducted at plant #102 on Swing Rd and documentation of training is retained at plant #102
Documentation that the training records are located at plant #102 is in plant #103 s SPPP Training records are available for
review
Mr Kitchen reviewed the SPPP which indicated that a single monitoring qualitative or analytical had been documented
since the previous inspection on July 6 2016 The Mr Weagerle reiterated that a discharge event may not be captured
because it is an unmanned plant and that they prevent discharges by keeping the truck wash basin volume to a minimum
Outfall #1 is located on the ledge of a weir at end of a storm/process water collection basin which is part of a truck wash
system The stormwater is collected in basins and used to wash vehicles therefore process water Stormwater is collected
in a settling basin and flows past a weir to a collection basin which is treated with Cot neutralization to control pH The
collection basin water is sometimes applied to the roads to control dust inside the plant If the collection basin fills it will
eventually discharge over a weir which is outfall #1 By keeping the water level below the weir discharges are avoided
therefore monitoring events are avoided at this location
During the August 27 2015 NCDENRICity of Greensboro inspection deficiencies for correction were noted which
recommended the addition of a berm and creation of an additional outfall (#2) Based on observations documented by Mr
Kitchen during the July 6 2016 Multimedia inspection and a Technical Assistance visit by Sue White and Glenn White on
July 22 2016 it was recommended that outfall #2 be constructed using berm consisting of a stable material other than
sand Mr Kitchen observed on July 3 2017 that concrete retaining wall had begun to replace the sand berm previously
noted poured concrete was also used in some areas Some damage to the berm was in the process of being repaired at
the time of the inspection No evidence of significant discharge was observed in the area of outWI #2
Admixtures stored in above ground storage tanks were located within spill containment The spill containment drain valve
was sealed and locked at the time of the inspection No vehicle maintenance is performed on site
Page 2

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 07/0312017 Inspection Type Compliance Evaluation Reason for Visit Routine
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a Narrative Description of Practices ?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been Implemented?
Yes No NA NE
■❑❑❑
M ❑ ❑ ❑
®❑ ❑ ❑
i ®❑ ❑ ❑
■❑❑❑
■❑❑❑
0 ❑ 1113
■❑❑❑
®❑❑❑
®❑❑❑
❑ ❑ ❑
■❑❑❑
Comment The Stormwater Pollution Prevention Plan (SPPP) was most recently reviewed and updated on
July 20-2016 The detailed site map Included the new outfall which was observed during the _
pervious inspection Employee training records are maintained at Plant 102 on Swing Rd
Qualitative Monitoring Yes No NA NE
Has the facility conducted Its Qualitative Monitoring semi annually? ®❑ ❑ ❑
Comment Qualitative monitorinq was documented on March 28, 2017
Analytical Monitoring
Has the facility conducted Its Analytical monitoring?
# Has the facility conducted Its Analytical monitonng from Vehicle Maintenance areas?
Yes No NA NE
■❑❑❑
❑ ❑ M ❑
Comment Analvtical monitorinq was conducted on March 28, 2017 No flow was recore for outfall #1 and
outfall #2 documented a pH of 7 6 and a TSS result of 14 6 mq/L result Outfall #1 is maintined.
so that stormwaterlprocess water discharged infrequently Process water collected in the truck
wash basin associated with outfall #1 utilizes Cot neutralization to control H
Permit and outfalls
Yes No NA HE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
# Were all outfalls observed during the inspection? ®❑ ❑ ❑
# If the facility has representative outfall status is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ®❑ ❑
Page 3

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 07/0312017 Inspection Type Compliance Evaluation Reason for Visit Routine
Comment 4utfall #2 was under_repatrs_at the time of the inspection Large concrete barrier blocks are
being used to replaced concrete poured over an earthen berm„ No„significant evidence of recent
discharctes were observed near outfalls 1 or 2 on the day of the inspection
Page 4

4
Augu!0; 2016,\
Mr Ted Chandler
Chandler Concrete
1006 S Church Street I 1 r
Burlington, NC 27215 '
Subject NOTIFICATION OF MONITORING REQUIREMENTS RELATED TO NPDES
PERMIT NCG140000 FOR STORMWATER, WASTEWATER AND
COMINGLED DISCHARGES
Dear Mr Chandler
Recently various personnel from Department of Environmental Quality have inspected Chandler
Concrete facilities in the Winston-Salem Region which includes Alamance County to Watauga
County and the northern NC state line to Randolph, Davie and Davidson Counties You've
either received, or will receive the Inspection Reports for each individual facility
For all of these facilities, there are 3 kinds of discharges to the waters of the state covered under
the NCG14000 permit Stormwater discharge, wastewater discharge and commgled discharge
(which is a mixture of stormwater and wastewater and is treated as wastewater)
Stormwater is monitored on a semi-annual basis at all outfalls January 1-June 30 is the first
time frame and July l-December 31 is the second During each six-month period, following a
significant storm event, a sample of the stormwater discharge must be obtained and analyzed by
a qualified laboratory for the parameters outlined in the NCGt40000 permit Part IV, Section
A, Table 1
Wastewater and/or comtngled water are monitored on a quarterly basis either from the
wastewater basins or comtngled water from all the outfalls January 1-March 31, April 1-June
30, July 1-September 30 and October 1-December 31 are the dates that signify the quarters
During each three-month period, during discharge from a basin or following a significant storm
event, a sample of the wastewater/comtngled discharge must be obtained and analyzed by a
qualified laboratory for the parameters outlined in the NCG140000 permit Part IV, Section D,
Table 7
During times of unusually low rainfall, or in the case of a recycle system where there is no
discharge from a basin, it is acceptable to record a finding of "NO FLOW" on the Discharge
Monitoring Report

L
The analytical results must be submitted to the Division on Discharge Monitoring Report (DMR)
forms no later than 30 days from the date that the facility receives the results Also, a copies of
all DMR's must be kept on site for a period of 3 years and available for review during
inspections
During the recent inspections of the Chandler Concrete facilities in this region it was noticed that
for the last several recording periods, all of the DMR's (Stormwater and Wastewater) have "No
Flow" written on them That indicates that for those recording periods, NO significant rain
events have occurred at any of the locations in the 15 county Winston Salem region Photos
taken at the various facility sites indicate differently showing incised areas around outfalls from
high velocity discharges and at two locations photos show where concrete slurry has made it to
water of the states which is a violation of the Clean Water Act and could be cause for a Notice of
Violations and assessment of associated fines
This office recommends that Stormwater/Wastewater Permit training be implemented for all of
the Chandler Concrete facilities so that possibility of non-compliance be minimalized Also,
please understand that these facilities will be monitored by NCDEQ inspectors on a more
frequent basis to ensure compliance
Should you have any questions regarding these matters, please contact Sue White at (336) 776-
9661
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
cc DEMLR - WSRO

Environmental
Quality
July 26, 2016
PAT MCCRORY
Governor
DONALD R VAN DER VAART
Serrerary
KINNi Ili WALGERLL-- CORPORA ILEHS MANAGI R
CI IANDI I R CONCRLTi /P[EDMON I INC -CI IIMNf Y ROCK RD PLAN 1 103
1006 A CHURCH S 1 REST
BURLING ION, NC 27216
Subject Multimedia Compliance Inspection
CHANDLER CONCRETE/P1I DMONT INC -CHIMNEY
ROCK RD PLANT 103
COUNTY Guilford
Dear Permittee
Department of Environmental Quality staff from the Winston-Salem Regional Office conducted a
multimedia compliance inspection of Chandler Concrete/Piedmont Inc - Chimney Rock Rd Plant 103
on July 6, 2016 for permits and programs administered by the following Divisions
Division of Air
Division of Energy,
Division of Water
Division of Waste
Quality
Mineral, and Land
Resources
Management'
Resources
We appreciate your cooperation during the inspection and hope that you have enjoyed the benefit of our
initiative to provide a single inspector capable of handling multiple areas of environmental compliance at
your facility The results of each applicable inspection and any associated response actions or necessary
corrective measures are detailed in the inspection letters/reports attached to this transmittal sheet (note
attached NOD dated July 8, 2016 was previously provided to you) If a Division report is not attached, you
may assume compliance with that particular Division's rules and regulations at the time of inspection
If you have any questions regarding this multimedia inspection, please contact Jack Kitchen at (919) 218-
8409 or Jack Kitchen@ncdenr gov Thank you for your cooperation
encl Air Quality Inspection Report
Stormwater Inspection Report
cc DAQ WSRO Files
DWR WSRO Files
State of North Carolina I Cnvironmaual Quality
Winston Salem Regional Office 1 450 West Hanes Mill Road Suite 300 1 Winston Salem North Carolina 2710, 7407
336 776 a800 T 1 336 776 9797 r

1
NORTH CAROLINA DIVISION OF
AIR QUALITY
Inspection Report
Date 07/12/2016
Facility Data
Chandler Concrete/Piedmont, Inc - Chimney Rock Rd Plant 103
114 North Chimney Rock Road
Greensboro, NC 27409
Lat 36d 4 6816m Long 79d 55 0683m
SIC 3273 / Ready -Mixed Concrete
NAICS 32732 / Ready -Mix Concrete Manufacturing
t
Contact Data
Facility Contact
Authorized Contact
Technical Contact
James Edwards
Kenneth Waegerle
Kenneth Waegerle
Plant Manager
Corporate EHS Manager
Corporate EHS Manager
[phone]
[phone]
[phone]
Winston-Salem Regional Office
Chandler Concrete/Piedmont, Inc - Chimney Rock
Rd Plant 103
NC Facility ID 4100992
County/FIPS Guilford/081
Permit Data
Permit 06142 / R09
Issued 2/21/2014
Expires 1/31/2022
Classification Small
Permit Status Active
Current Permit Application(s) None
Program Applicability
SIP
,
Compliance Data
Comments Mullimcdta Inspection
Inspection Date 07/06/2016
Inspector's Name Jack Kitchen
Inspector's Signatum Operating Status Operating
Compliance Code Compliance - inspection
Action Code FCE
On -Site Inspection Result Compliance
Date of Signature July 14, 2016 RS
Total Actual emissions in TONSNEAR
TSP
S02
NOX
VOC
CO
PM10
* HAP
2012
0 1 100
---
---
---
---
00500
- -
2008
0 1500
---
---
---
00700
---
Five Year Violation History None
Date Letter Type Rule Violated
Performed Stack Tests since last FCE None
Date Test Results Test Methods)
* Highest HAP Emitted (in pounds
Violation Resolution Date
Source(s) Tested

Permitted Sources
Emission Emission Source Control
Source 1D I Description I System ID
Control System
I Description
One Truck -Mix Concrete Batch Plant (90 cubic yards per hour maximum capacity) consisting of
ES -I
Cement storage silo
CD -I
Bagfilter (1,490 square feet of filter area)
ES-2
Flyash storage silo
ES-3
Cement/flyash weigh hopper
ES-4
Truck loadout operation
Insignificant/Exempt Sources
Source Exemption Source ofTAPs Source of Title V
Regulation Pollutants
F I -- one natural gas -fired hot water F
Q 0102(c)(2)(B)(ii) Yes Yes
heater (0 825 million Btu per hour
maximum heat input capacity)
1-2— concrete admixture tanks 2Q 0102(c)(1)(L)(xn) No Yes
(500-2,400 gallons capacity, range)
Introduction
On July 6, 2016, Mr Jack Kitchen, inspector with NCDEQ met with Ken Waegerle Environmental, Health, and Safety
Manager and James Edwards, Plant Manager, of Chandler Concrete/Piedmont, Inc - Chimney Rock Rd Plant #103 for an
announced Multimedia compliance inspection This facility was previously inspected by Davis Murphy, DAQ Inspector, on
July 25, 2014 According Mr Murphy s inspection report, the facility appeared to be in compliance with Air Quality
standards and regulations at the time of the inspection Plant 9103 is a truck mix, concrete, batch plant The plant operating
hours are flexible due to an inconsistent demand for concrete production Currently, Mr Edwards works at Chandler s nearby
Swing Rd facility, Plant #102 Plant 4103 on Chimney Rock Rd is a "backup' facility that is remotely operated from the
control room of Plant #102 on Swing Rd They estimated that Plant 4103 is operated on average once a month to supplement
at the Swing Rd plant when demand requires additional production The plant was not operating on the day of the inspection
(BEAM contact information was reviewed and updated Required safety equipment on this site includes safety shoes,
hardhat, safety glasses, hearing protection and a safety vest
Applicable Reaulatzons
According to permit Condition A 1, the facility is subject to the following regulations Title 15A North Carolina
Administrative Code (NCAC), Subchapter 2D 0202, 2D 0515, 2D 0521, 2D 0535, 2D 0540, 2D 0611 2D 1806 and 2Q
0309 This facility is not subject to RMP requirements of the 112(r) program since it does not use or store any of the
regulated chemicals in quantities above the threshold levels in the rule The facility is only subject to the General Duty
requirements contained in the General Duty Clause
Oiiieratine Status/Discussion
This facility is a truck mix concrete batch plant This facility utilizes a cement storage silo (ES-1) and flyash storage silo (ES-
2) located side by side Each silo auger feeds to a weigh hopper (ES-3) that discharges to the truck loadout (ES-4) Emissions
from all of these sources are controlled by a baghouse, consisting of 1,490 square feet of bagfilter area (CD-1) .The collected
dust from this bagfilters is recycled back into the fly ash silo Although the facility was not observed in operation during the
inspection, Mr Kitchen inspected ductwork and the exterior of the baghouse All ducts appeared to be in good condition
with visible no holes or breaks The exterior of the baghouse looked to be in good condition with no accumulation of dust or
evidence of bagfi [ter failure

Aggregate and sand that is stored in piles on the property is loaded and conveyed into a weigh hopper The cement and flyash
are dispensed from silos into a weigh hopper The particulate emissions generated during loading the weigh hopper is
exhausted through the central collection bagfilters The dry contents of the hopper are discharged into a mixing truck During
truck loadout, emissions are suppressed by a shroud placed around the mixing dnim s input lot Particulate emissions
generated during truck loading is vented to bagfilter Water is dispensed into the truck Water is heating using an electric hot
water heater during colder times of the year Records reviewed at the facility denote that the plant produced 8,596 yds3 of
concrete during the calendar year 2015 The records document the facility produced 84 75 yds3 of concrete from January 1,
2016 to July 6, 2016 Finally, mixing trucks are washed in basin to prevent fugitive emissions leaving the property
Permit Con ditions/A hcable Regulations
Condition A 2 contains 15A NCAC 2D 0202 permit renewal and emissions inventory requirements The permit expired
March 31, 2014 and the facility was required to submit a renewal request and air pollution emission inventory report for the
2012 calendar year 90 days prior to the expiration of the permit A renewal application and CY2012 Emission Inventory was
received by the DAQ-WSRO on January 2, 2014 and Air Permit 061421109 was issued on February 21, 2014 Compliance
was demonstrated
Condition A .i' contains the 15A NCAC 2D 0515 particulate control requirement This condition sets the maximum
allowable particulate emissions using the following two equations
E = 4 10 * (P) ° 67 for P <= 30 tonslhr, or
E = 55 * (P) ° " - 40 for P >30 tonslhr
According to emission calculations performed during permit review R09 using the NCDENR Concrete Batch Plant
Emissions Calculator, the weigh hopper and fly ash silo both require a control device to achieve compliance with this rule
while the cement silo and loadout can comply uncontrolled The dust collector (CD-1) appeared to be properly installed and
sufficiently maintained, therefore, compliance is expected
Condition A 4 contains the 15A NCAC 2D 0521 visible emissions control requirement This facility is limited to 20%
opacity visible emissions when averaged over a six -minute period The facility was not operating during the inspection and
no visible emissions were observed and no evidence of malfunctions or accumulated cement or fly ash on the outside of the
exhaust outlet of CD-1 Compliance is expected
Condition A S contains the 15A'NCAC 2D 0535 rule which requires the permittee to notify the director of any excess
emissions lasting longer than four hours resulting from a malfunction, a breakdown of process or control equipment or any
other abnormal conditions Mr Edwards and Mr Waegerle stated that no such incidents had occurred indicating compliance
with 2D 0535
Condition A 6 contains the 15A NCAC 2D 0540 fugitive dust control requirement Mr Edwards and Mr Waegerle stated
the facility was in operation for only 288 hours in 2015 and they did not take any control measures According to the DAQ
IBEAM database and facility file, no complaints have been received regarding fugitive dust emissions at this facility
Compliance with 2D 0540 is expected
Condition A 7 contains the I SA NCAC 2D 0611 bagfilter inspection, maintenance, and recordkeeping requirements for
particulate matter emissions control The facility is required to perform, at a minimum, an annual (for each 12-month period i
following the initial inspection) internal inspection of each bagfilter system and perform periodic inspection and maintenance
as recommended by the' equipment manufacturer The facility is required to record the results of all inspection and
maintenance activities in a iogbook The facility maintains a bagfiiter filter logbook that was reviewed and found to be in
compliance The most recent inspections of the system were documented on April 4, 2016 and March 12, 2015 Compliance
with 2D 0611 was demonstrated
Condition A 8 contains the 15A NCAC 2D 1806 control and prohibition of odorous emissions requirements No
objectionable odors were detected during the approach to the facility or within the property boundaries The facility does not
have any previous odor complaints in the IBEAM database Compliance with 2D 1806 is expected

New Source Performance Standards NSPS & N ti nal Emission Standards for Hazardous Air Pollutants NESHAP
Mr Kitchen did not observe emergency generators on site Mr Waegerle and Mr Edwards state that the facility does not
have any A small natural gas fired hot water heater is used to heat water during winter months Because the unit is natural
gas -Fred, it is not Subject to 40 CFR Part 63 Subpart JJJJJj This facility does not appear to be subject to any NSPS or
NESHAP rules at this time
Facility Wide Emissions
The facility wide actual emissions from the CY2012 emission inventory are located in the report header The facility has
operated for 84 75 hours year to date producing a total 8,553 cubic yards of concrete
Permit Issues
There do not appear to be any permit issues at this time, however, Mr Waegerle stated that the company is considering
operations without a permit in light of recent state air permit exemption rules
Source Tests
No stack testing or VE testing has ever been conducted at this facility
Com Hance 11%§Jory
This facility has not been issued any Notices of Violation or Deficiency in the previous five years
Conclusion
Based on the inspector s observations and review of available records, this facility appeared to be operating in compliance
with Air Quality standards and regulations at the time of this inspection

Compliance Inspection Report
Permit NCG140232 Effective 07/01/16 Expiration 06/30/17 Owner Chandler Concrete/Piedmont Inc
SOC Effective Expiration Facility Central Concrete Co Chimney Rock Road Plt 4103
County Guilford 114 N Chimney Rock Rd
Region Winston-Salem
Greensboro NC 27409
Contact Person Kenneth E Waegerle Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC Certification Phone
Secondary ORC(s)
On -Site Representative(s)
Related Permits '
Inspection Date 07106/2016 Entry Time 01 15PM Exit Time 02 36PM
Primary Inspector Jack Kitchen Phone [phone]
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Ready Mix Concrete StormwaterMastewater Discharge COC
Facility Status 0 Compliant Not Compliant
Question Areas
Storm Water
(See attachment summary)
Page 1

Permit NCG140232 Owner Facility Chandler Concrete/Piedmoni Inc
Inspection Date 0710612016 Inspection Type Compliance Evaluation Reason for Visit. Routine
Inspection Summary
On July 6 2016 Jack Kitchen Compliance Inspector with the North Carolina Department of Environmental Quality
conducted a Multimedia Compliance Inspection at Chandler Concrete Company -Plant #103 The inspector met with Ken
Weagerle, Environmental Health and Safety Manager and James Edwards Plant Manager who provided the inspector
access to the facility s equipment and available records
Plant #103 is a remote location at 114 N Chimney Rock Rd in Greensboro and controlled by Swing Road Plant #102 No
employees are stationed on site Plant #103 operated 288 hours in 2015 as a backup for other Chandler batch plants
predominantly for plant #102 Only 8 596 cubic yards of concrete were produced in 2015 and 84 75 cubic yards were
produced this year to date
Employee training is conducted at plant #102 on Swing Rd and documentation of training is retained at plant #102
Documentation that the training records are located at plant #102 is in plant #103 s SPPP Mr Edwards made the training
records from plant #102/#103 available for review at the time of the Inspection
Mr Kitchen reviewed the SPPP which indicated that no monitoring qualitative or analytical had been documented since
9/1712014 The Mr Weagerle stated that there had not been a discharge event captured / No Flow because it is an
unmanned plant and that they prevent discharges by keeping the truck wash basin volume to a minimum Outfall #1 is a
spillway at end of a truck wash basin The Stormwater is collected in the basin and used to wash vehicles therefore
processwater Mr Weagerle explained that the water that is collected in the settling basin is pumped into trucks and
hauled off site to plant #103 and applied to the roads to control dust By keeping the water level below the discharge point
of Outfall #1 discharges are avoided therefore monitoring events are avoided at this location Storm water and process
water which has not received analytical monitoring is removed and applied to the ground at property with a separate
SPPP
Admixtures stored in above ground storage tanks were located within spill containment The spill containment drain valve
was sealed and locked at the time of the inspection
The facility submitted a permit renewal request on June 30 2016 A General Permit has been reissued with no changes for
one year effective July 1 2016 The permit expires June 30, 2017 During the August 27 2015 NCDENRICity of
Greensboro inspection conducted by Sue White and Glen White of NCDEQ deficiencies for correction were noted which
recommended the addition of a berm and creation of an additional outfall (#2) During the inspection a berm and second
outfall were observed (photos are located in the facility file) Mr Waegerle stated that the berm and out fall were still under
construction and would be included SWP3 The current SPPP and site map does not include outfall #2 Monitoring has not
been conducted at outfall #2 On the day of the inspection there did not appear to be signs of erosion or failures around
outfalls #1 or #2
Based on observations documented by the Inspector during the July 6 2016 Multimedia inspection it is recommended that
facility's compliance status be reviewed by DEMLR's Stormwater Program to determine if monitoring violations have
occurred and if the construction of outfall #2 was performed in compliance The procedure of transporting storm water
and/or process water from one facility to another should also be reviewed by DEMLR staff
Page 2

Permit NCG140232
Inspection Date 0710812016
Owner Facility Chandler ConcretelPiedmont Inc
inspection Type Compliance Evaluation Reason for Visit. Routine
Analybcal Monitonng Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical mondonng from Vehide Maintenance areas? ❑ ❑ E ❑
Comment According_tQ_Ken Waegerle, no measurable storm event resulting in discharge at the outfall
occured during work hours and/or while personnel were on site from September 17, 2014 until
July 6, 2016 Most recent analytical monitoring was performed on September 17, 2014 (pH 8 2,
TSS 5 5 mq/L) s
Newly constructed outfall #2 is not included in the 2015 revision of the SPPP_ Outfall #2 was
observed on the day of the inspection and no Analvtical Monitoring has been documented from
this outfall
No vehicle maintenance is conducted at this location
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? S ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status is it properly documented by the Division? ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑
Comment The facility submitted a permit renewal request on June 30, 2016 A General Permit has been
reissued with no changes for one year effective July 1. 2016
Qualitative Monitorina Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? ❑ ❑ 110
Comment According to Ken Waegerle, no measurable storm event resulting in discharge at the outfall
occured during work hours and/or while personnel were on site from September 17, 2014 until
July 6, 2016
Newly constructed_ outfall #2 is not included in the 2015 revision of the SP_PP Outfall #2 was
observed on the day of the inspection and no Qualitative Monitoring has been documented from
this location
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 ? E ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas? 0 N ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑
Page 3

permit NCG140232 owner Facility Chandler Concrete)Piedrront Inc
Inspection Date 07/06/2016 Inspection Type Compliance Evaluation Reason for Visit Routine
5tormwater Pollution Prevention Plan
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Yes No NA NE
■❑❑❑
®❑❑❑
■ ❑ ❑ ❑
E ❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
■❑❑❑
Comment Because the facility is remotely operated and no employees are stationed at this location on a
daily basis, employees are trained at plant #102 on Swing Rd in Greensboro Documentation
of the training is maintained at plant #102 and It is noted in the plant #103 log Because the
inspection was announced, the facility contact was able to provide plant #103 documents
Dunne the August 27, 2015 NCDENR/City of Greensboro Inspection, deficiencies for correction
were noted, which recommended the addition of a berm and creation of an additional outfall_0Q),
which would require same analytical sampling as outfall #1 During the Inspection, a berm and
second outfall were observed Ken Waegerle stated that the berm and outfall were
underconstructlon and would be included in the next revison of the SPPP The current SPPP
and site map does not Include the berm and outfall #2
Page 4

1C.
Ener�'y,>weierat&
LandK>3swavw
BNVlgGyiNig A*WrAW
July B, 2016
PAT lvlcCPOIiY
Baernae
DONALD R VAN DER VAAkT
sb=ftry
TRACY DAVIS
CERTIFIED MAIL 7015 0640 0005 8164 452E CERTnUM MAIL 7015 0640 0005 8164 4511
RETUILN RECEIPT REQUESTED RETURN RECLIPT REQUESTED
Attn Ted Chandler
Attu Kenneth E Waegerle
Chandler Concrete Co, Tin
Chandler Concrete Co , Inc
1006 A. Church Street
1006 A Church Street
Burlington, NC 27216
Burlington, NC 27216
Subject NOTICE OF DISCREPANCIES
NOD 2016-SP-0001
Pernut# NCG140232
Chandler Concrete — Chimney Rock Rd Plant 4103
Guilford County
Dear :VIr Chandler
On July 06, 2016 Jack Kitchen, Tnspeclor with the NCDFQ (North Carolina Department of
Environmental Quality's) Multimedia inspection Team, met with Ken Waegerle (Environmental Health
and Safety Manager) and James Edwards (Plant Manager) at the facihty located at 114 N Chimney Rock
Road in Greensboro, to conduct an inspection to verify compliance with the facilities stormwater permit
requirements Tire inspection consists of review of the Stormwater Pollution Prevention Plan, training,
monitoring and spills records as well as observation of the general condition of the site, the outfalis and
any possible exposures to downstream storrawater
Chandler Concrete holds General Stormwater Permit NCO140232 to discharge stormwater from
industrial activity associated with Ready MAed Concrete & like Aettvities under the National Pollutant
Discharge Elimination System (NPDES) The permit became effective July 01, 2011 and expires on
June 30 2016
This facility is remotely operated by the Swrrmg Rd Plant # 102 No employees are based at the Chimney
Road Rd facility but supplies are brought to the site periodically and whenever the fauhty is used, trucks
pick-up and deliver concrete batches The truck wash is also used regularly So even thougb this plant is
remotely operated, it still has the same possible exposures as fimlly manned plants and therefore is not
exempt from bi-annual monitoring requirements
ftft& xthCwo&m& I tnWrav=ddQadty 12aaW"nerdandlamdPmoLm"
wKq rW=RV0WjWFm* 14SO.HMMtowtoed aftsocr I waetarulam m MOB
U6 M V"

Acoordingly, the following observations and violations were noted dumig the NCDEQ Multimedia
Inspection and subsequent file review
Ooalitatlye Moniturlm[
General Permit NCG140000, Part IV Section C. requires the facility to oonduct qualitative monitoring
twice per year following the established guidelines Inspecbon revealed that no qualitative monitoring
has been conducted at the facaltty since 09/17/2014 Monitoring must be completed twice annually and
records must be kept with the SPPP far a mmimum of five (5) years
Anatyhgg Manttorin$
General Permit YCG 140000, Part IV Section A requires the facility to conduct. Analytical Monitonng
twice annually at each of tie facrhties stormwater outfaUs The current general permit only requires
sampling for TSS (Total Suspended Solids) and pH semi-annually Monitoring must be completed twice
annually and records must be kept with the SPPP for a minimum of five (t) years
Required lEtmnse
Accordingly, you are directed to respond to this letter in writing within 30 calendar days of reeerpt of
this Notice Your response should outline how violations will be addressed and should be sent to this
office at the letterhead address and include the following
l Perform Qualitiative Monitoring twice annually beep monitoring records in SPPP binder
Perform Analytical Monitoring twice annually as per permit requirements defined in Part IV,
Soction A#
Please dtiect your response and any questions regarding this letter to Glen White at (3 3 6)776-9661
Sincerely,
Matthew E Gantt, P F
Regional Engmeer
Land Quality Section
Winston-Salem Regional Office
Enclosures Inspection Report
= File Copy Divasian of Energy, Mineral and Land Resources (WSRO)
l 4wrAhawXamuft>«ta I tna�mn xio aim
WO M9saa

,a.
A, al.
Energy Mineral &
Land Resources
ENVIRONMENTAL QUALITY
July 25, 2016
Attn Ken Waegerle
Chandler Concrete Co , Inc,
1006 A Church Street
Burlington, NC 27216
Subject Technical Assistance Report
Permit# NCG140232
Chandler Concrete Chimney Rock Rd Plant # 103
Guilford County
Dear Mr Chandler
PAT McCRORY
Cover nor
DONALD R VAN DER VAART
Secretary
TRACY DAVIS
Dlrt'ctor
On Friday, July 22, 2016 Glen White and Sue White, Stormwater Inspectors with NCDEQ's Winston-
Salem office and jack Kitchen, NCDEQ Multi -Media Inspector met with you at your request following
receipt of i Notice of Discrepancy at Chandler's Chimney Rock Road Plant The discrepancy was issued
for failure to monitor in accordance with the facility Stormwater Permit
At this visit we determined that the truck wash out basin had been pumped down before the inspection but
it could not be determined whether or not this outfall has produced a discharge The wet high water line
stain was observed to be near the basin weir which would suggest that water has moved through the weir
New gravel obscured any possible evidence of a discharge Mr Waegerle states that the basin is pumped
down on a regular basis and uses the' No Flow" statement for this basin instead of conducting bi-annual
monitoring Rainfall records will need to be verified for this area since there should have been significant
rainfall to produce a probable discharge even with pump down NCDEQ will need to conduct
unannounced inspections to verify that no discharges are taking place
Outfall 2 was created by adding a berm and PVC pipe at the City of Greensboro's request The berm was
created out of sand I his is not a suitable nor stable material and it is washing downstream significantly
It's not safe for anyone that may be conducting monitoring as it collapses down the slope just from
standing on it The berm needs to be constructed from more appropriate materials such as vegetated clay,
wasted concrete, asphalt or other permanent and stable material It was determined that this outfall has
produced significant discharge and both analytical and qualitative monitoring need to be conducted in
accordance with the permit
State of North Carolina I Environmental Quality i Energy Mineral and Land Resources
Winston Salem Regional Office 1 450 Hanes Mill Road Suite 300 1 Winston Salem NC 77103
336 776 9800

It was determined that since this facility is "not dormant" and must abide by the same rules as facilities
that operate full-time the plant is run remotely from the Swing Road facility Therefore, the Plant
Manager for the Swing Road plant will be responsible for maintaining the SPPP, pumping down the basin
at regular intervals and for ensuring that monitoring is conducted at Outfall 2 as per the permit
All records for this site and all other facilities that are required to maintain Stormwater Permits are subject
to unannounced inyections to determine compliance This facility may by inspected at any time
without notice the SPPP (Stormwater Pollution Prevention Plan) must be updated and available for
review upon the inspector's arrival Monitoring and training records must be current and maintained with
the SPPP
Please direct any questions regarding this letter or your Stormwater Permit to Glen White at (336)776-
9660
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures inspection Report
cc File Copy Division of Energy, Mineral and Land Resources (WSRO)
State of North Carohna I Environmental Quality I Energy Mineral and Land Resources
Winston Salem Regional Office 1 450 Hanes Mill Road Sulte 300 1 Winston Salem NC 27103
336 776 9800

l
Permit NCG140232
SOC
County Guilford
Region Winston Salem
Compliance Inspection Report
Effective 07/01/16 Expiration 06/30/17 Owner Chandler Concrete/Piedmont Inc
Effective Expiration Facility Central Concrete Co Chimney Rock Road Plt #103
114 N Chimney Rock Rd
Contact Person Kenneth E Waegerle Title
Directions to Facility
System Classifications
Primary ORC
Secondary ORC(s)
On Site Representative(s)
Related Permits
Inspection Date 07/22/2016 EntryTime 10 00AM
Primary Inspector Glen White
Secondary Inspector(s)
Greensboro NC 27409
Phone [phone]
Certification Phone
Exit Time 11 OOAM
Phone [phone]
Reason for Inspection Routine Inspection Type Technical Assistance
Permit Inspection Type Ready Mix Concrete StormwaterfWastewa ter Discharge COG
Facility Status ❑ Compliant ❑ Not Compliant
Question Areas
Storm Water
(See attachment summary)
Page 1

Permit NCG140232 Owner Facility Chandler Concrete)Piedmont Inc
Inspection Date 07/22/2016 Inspection Type Technical Assistance Reason for Visit Routine
Inspection Summary
(See Technical Assistance Letter)
Page 2

Permit NCG140232 owner Facility Chandler ConcretelPiedmont Inc
Inspection Date 07/22/2015 Inspection Type Technical Assistance Reason for Visit Routine
Analytical Monitoring
Has the facility conducted Its Analytical monitormg>
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
❑■❑❑
❑ ❑ E ❑
Comment No monitoring performed since 2014 Site may recieve unannounced Inspections to verify No
Flow' statement for the truck wash basin At the time of inspection the basin appeared to have
been pumped down shortly before the visit There was an established waterline near the
elevation of the basin weir which would indicate a possible discharge New gravel at the outlet
obscured the ability to verify at that time
Outfall 2 - has had no monitorina althouah monitorina is reauired by the permit and there has
been obvious discharge including sand from the berm washing downstream Will need to verify
future compliance
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# Were all outfalls observed during the inspection? ® ❑ ❑ ❑
# If the facility has representative outfall status is it properly documented by the DivlsioO ❑ N 1111
# Has the facility evaluated all illicit (non stormwater) discharges> ® ❑ ❑ ❑
Comment Outfall 2 - The berm Is poorly constructed It is made of sand and unstable and erosin
significantly Sand is the least viable material choice for a berms construction The berm needs
to be constructed of a stable material such as clay, concrete, aspalt or other stable material It
also needs to be stabilized permanently If its earthen it needs to be vegetated
Improvements will be verified at the time of unannounced inspection
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? ❑ M ❑ ❑
Comment Accordin4to Ken Waegerle the facility has not received a measurable storm event since 2014
and the basin used to settle out sediment from truck was is pumped down to prevent a
discharge All recent qualitiative records are marked "no flow " This has not been verified
The second outfall has had significant discharge and is significantly eroding Verified at this site
visit
Unannounced inspections may be conducted in the future at this and other facilities to verity
compliance
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stofmwater Pollution Prevention Plan) ■ ❑ ❑ ❑
Page 3

Permit NCG140232 Owner Facility Chandler ConcretelPledmontInc
Inspection Date 07/2212016 Inspection Type Technical Assistance Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
# Does the Plan Include a General Location (USGS) map?
■ ❑ ❑ ❑
# Does the Plan include a Narrative Description of Practices ?
E❑ ❑ ❑
# 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?
® ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
N ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan Include a BMP summary?
® ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan Include a Preventative Maintenance and Good Housekeeping Plan?
® ❑ ❑ ❑
# Does the facility provide and document Employee Training?
■ ❑ ❑ ❑
# Does the Fan Include a list of Responsible Party(s)?
■ ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
N ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been Implemented?
0 ❑ ❑ ❑
Comment SPPP Is required to be maintained onslte Please maintain the SPPP for each Chandler facility
at _ that Individual facilityfor matntaming it ._.
and for review at any time
Unannounced Inspections may conducted at this and other facilities to verify compliance
Page 4

.�41Lfie"
Lnergy Mineral &
Land Resources
ENVIRONMENYAL QUALITY
July 25, 2016
Attn Ken Waegerle
Chandler Concrete Co , Inc
1006 A Church Street
Burlington, NC 27216
Subject Technical Assistance Report
Permit# NCG140232
Chandler Concrete — Chimney Rock Rd Plant 4103
Guilford County
Dear Mr Chandler
PAT McCRORY
covernnr
DONALD R. VAN DER VAART
Secretory
TRACY DAVIS
Dinxior
On Friday, July 22, 2016 Glen White and Sue White, Stormwater Inspectors with NCDEQ's Winston-
Salem office and Jack Kitchen, NCDEQ Multi -Media Inspector met with you at your request following
receipt of a Notice of Discrepancy at Chandler's Chimney Rock Road Plant The discrepancy was issued
for failure to monitor in accordance with the facility Stormwater Permit
At this visit we determined that the truck wash out basin had been pumped down before the inspection but
it could not be determined whether or not this outfall has produced a discharge The wet High water line
stain was observed to be near the basin weir which would suggest that water has moved through the weir
New gravel obscured any possible evidence of a discharge Mr Waegerle states that the basin is pumped
down on a regular basis and uses the "No Flow" statement for this basin instead of conducting bi-annual
monitoring Rainfall records will need to be verified for this area since there should have been significant
rainfall to produce a probable discharge even with pump down NCDEQ will need to conduct
unannounced inspections to verify that no discharges are taking place
Outfall 2 was created by adding a berm and PVC pipe at the City of Greensboro's request The berm was
created out of sand This is not a suitable nor stable material and it is washing downstream significantly
It's not safe for anyone that may be conducting monitoring as it collapses down the slope just from
standing on it The berm needs to be constructed from more appropriate materials such as vegetated clay,
wasted concrete, asphalt or other permanent and stable material It was determined that this outfall has
produced significant discharge and both analytical and qualitative monitoring need to be conducted in
accordance with the permit
St +rt of Noi rh Carolnta I Environr ntal Quaitty I Emryy Minual and Land Rf LOUI ,
Winston S ik nt Regional 0f hct I h0l l lncti N fl Road Suite it)o Mntifon Salem N( >tlo )
3 U, 116 4800

It was determined that since this facility is "not dormant" and must abide by the same rules as facilities
that operate full-time The plant is run remotely from the Swing Road facility Therefore, the Plant
Manager for the Swing Road plant will be responsible for maintaining the SPPP, pumping down the basin
at regular intervals and for ensuring that monitoring is conducted at Outfall 2 as per the permit
All records for this site and all other facilities that are required to maintain Stormwater Permits are subject
to unannounced inspections to determine compliance This facility may by inspected at any time
without notice The SPPP (Stormwater Pollution Prevention Plan) must be updated and available for
review upon the inspector's arrival Monitoring and training records must be current and maintained with
the SPPP
Please direct any questions regarding this letter or your Stormwater Permit to Glen White at (336)776-
9660
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
a DOmestic Mail OnlyG
U
-� Gerllfi9d MaU Fee
co s r✓i5i'(e,(
A'10ExtIA(
Ln O R Servic 0 �(� ecu eaaree as N� 1 U Retain R epwopriereJ W 7 L
p Q stehm Receipt (I S
a Cen,sed Mau Rastrictea 6 Postmark
0 [1 Adu@ Signet,. RN,.bw Here
!^
❑Adult Stgnet. Restricted
S Postage
p Total Po*
�$
ent To Chandler Concrete Co , Inc
$7BBfan Attn Kenneth E Waegerle
Z'rfr star 1006 A Church Street
Burlington, NC 27216
Enclosures Inspection Report
cc File Copy Division of Energy, Mineral and Land Resources (WSRO)
Simi <if N'orylt GAidina I Lnviionnrenm] Qataldti I t III rtt} hlmrral ancd I )nd Rtsourci 5
Wtn UM Salem Hcywnai OtftcL 1 W Hancs Mill Road Suite = I A° fwwri S<t{(rn NC 27W
310 7r 6')BOO

Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
July 8, 2016
CERTIFIED MAIL 7015 0640 0005 8164 4528
RETURN RECEIPT REQUESTED
Attn Ted Chandler
Chandler Concrete Co, Inc
1006 A Church Street
Burlington, NC 27216
Subject NOTICE OF DISCREPANCIES
PAT MCCRORY
Govet nor
DONALD R VAN DER VAART
Secretary
TRACY DAVIS
Director
CERTIFIED MAIL 7015 0640 0005 8164 4511
RETURN RECEIPT REQUESTED
Attn Kenneth E Waegerle
Chandler Concrete Co , Inc
1006 A Church Street
Burlington, NC 27216
NOD-2016 -
Permrt# CG14023
Chandler oncrete — Clumney Rock Rd Plant #103
Guilford County
Dear Mr Chandler
On July 06, 2016 Jack Kitchen, Inspector with the NCDEQ (North Carolina Department of
Environmental Quality's) Multimedia Inspection Team, met with Ken Waegerle (Environmental Health
and Safety Manager) and James Edwards (Plant Manager) at the facility located at 114 N Chimney Rock
(toad in Greensboro, to conduct an inspection to verify compliance with the facilities stormwater permit
requirements The inspection consists of review of the Stormwater Pollution Prevention Plan, training,
monitoring and spills records as well as observation of the general condition of the site, the outfalls and
any possible exposures to downstream stormwater
Chandler Concrete holds General Stormwater Permit NCG140232 to discharge stormwater from
industrial activity associated with Readv Mixed Concrete & like Activities under the National Pollutant
Discharge Elimination System (NPDES) The permit became effective July 01, 2011 and expires on
June 30, 2016
This facility is remotely operated by the Swing Rd Plant #102 No employees are based at the Chimney
Road Rd facility but supplies are brought to the site periodically and whenever the facility is used, trucks
pick-up and deliver concrete batches The truck wash is also used regularly So even though this plant is
remotely operated, it still has the same possible exposures as fully manned plants and therefore is not
exempt from bi-annual momtoring requirements
State Of North Carolina [ Environmental Quality I Energy ?Aneral and Land Resources
Winston Salem Regional Office 1 450 Hanes Mill Road Suite 300 1 Winston Salem NC 27103
336 T76 9800

Accordingly, the following observations and violations were noted during the NCDEQ Multimedia
Inspection and subsequent file review
Qualitative Monitoring
General Permit NCG140000, Part IV Section C requires the facility to conduct qualitative monitoring
twice per year following the established guidelines Inspection revealed that no qualitative monitoring
has been conducted at the facility since 09/17/2014 Monitoring must be completed twice annually and
records must be kept with the SPPP for a mimmum of five (5) years
Analytical Monitoring
General Permit NCG140000, Part IV Section A requires the facility to conduct Analytical Monitoring
twice annually at each of the facilities stormwater outfalls The current general permit only, requires
sampling for TSS (Total Suspended Solids) and pH semi-annually Monitoring must be completed twice
annually and records must be kept with the SPPP for a minimum of five (0 years
Required 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 violations will be addressed and should be sent to this
office at the. letterhead address and include the following
1 Perform Qualitiative Monitoring twice annually Keep monitoring records in SPPP binder
2 Perform Analytical Monitoring twice annually as per permit requirements defined in Part IV,
Section A
Please✓ direct your response and any questions regarding this letter to Glen White at [phone]
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures Inspection Report
cc bile Copy Division of Energy, Mineral and Land Resources (WSRO)
State of North Carolina I Environmental Quality I Energy Mineral and Land Resources
Winston Salem Regional Office 1 450 Hanes MITI Road Suite 300 1 Winston Salem NC 27103
336 776 9800

Compliance Inspection Report
Permit NCG140232 Effective 07/01/16 Expiration 06/30/17 Owner Chandler Concrete/Piedmont Inc
SOC Effective Expiration Facility Central Concrete Co Chimney Rock Road Pit #103
County Guilford 114 N Chimney Rock Rd
Region Winston Salem
Greensboro NC 27409
Contact Person Kenneth E Waegerle Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC Certification Phone
Secondary ORC(s)
On Site Representative(s)
Related Permits
Inspection Date 07/06/2016 Entry Time 01 1 SPM Exit Time 02 36PM
Primary Inspector Jack Kitchen Phone 919 21S 8409
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Ready Mix Concrete StormwaterAVastewater Discharge CQC
Facility Status ❑ Compliant ® Not Compliant
Question Areas
® Storm Water
(See attachment summary)
Page I

Permit NCG140232 Owner Facility ChandterConcrelelPiedmontInc
lnspectton Date 07/06/2016 Inspection Type Compliance Evaluation Reason for Visit Routine
Inspection Summary
On July 6 2016 Jack Kitchen Compliance Inspector with the North Carolina Department of Environmental Quality
conducted a Multimedia Compliance Inspection at Chandler Concrete Company - Plant #103 The inspector met with Ken
Weagerle Environmental Health and Safety Manager and James Edwards Plant Manager who provided the inspector
access to the facility's equipment and available records
Plant #103 is a remote location at 114 N Chimney Rock Rd in Greensboro and controlled by Swing Road Plant #102 No
employees are stationed on site Plant #103 operated 288 hours in 2015 as a backup for other Chandler batch plants
predominantly for plant 9102 Only 8 596 cubic yards of concrete was produced in 2015 and 84 75 cubic yards was
produced this year to date
Employee training is conducted at plant #102 and documentation of training is retained at #102
Mr Kitchen reviewed the SWP3 which indicated that no monitoring qualitative or analytical, had been documented since
9/1712014 The Mr Weagerle stated that there had not been a discharge event captured because it is an unmanned
plant and that they prevent discharges by keeping the truck wash basin volume to a minimum Outfall #1 is a spillway at
end of a truck wash basin I was told that the water in the settling basin is pumped into trucks and hauled off site to plant
#103 and applied to the roads to control dust By keeping the water level below the discharge point of Outfall #1 discharges
are avoided therefore monitoring events are avoided
The facility submitted a permit renewal request on June 30 2016 A General Permit has been reissued with no changes for
one year effective July 1 2016 The permit expires June 30 2017 During the August 27 2015 NCDENR1City of
Greensboro inspection conducted by Sue White and Glen White of NCDEQ deficiencies for correction were noted which
recommended the addition of a berm and creation of an additional outfall (#2) During the inspection a berm and second
outfall were observed (photos are located in the facility file) Ken Waegerle stated that the berm and out fall were still under
construction and would be included SWP3 The current SWP3 and site map does not include outfall #2 Monitoring has
not been conducted at outfall #2 On the day of the inspection there did not appear to be signs of erosion or failures around
outfalls #1 or #2
Based on observations documented by the Inspector during the July 6 2016 Multimedia inspection it is recommended that
facility s compliance status be reviewed by DEMLR s Stormwater Program to determine if monitoring violations have
occurred and if the construction of outfall #2 was performed in compliance
'r
co
ru
ru
llY tf
(L Q A L � E
ls")
$
�Qi ha 1
.A
Postage
Ceruiied Fee
k-G l to el I � t
,-�
Postmark
ru
©
Return Receipt Fee
(EndorsementRequrred)
I - Hera
1 rA6.)" �1�
hr
©
C3
nestncted Delivery Fee
(Endorsement Required)
C3
r-q
Total F
r`
r'l
Maynnead Materials Inc
m
r-q
Fc�tytesof
Attn Willie B Roark
1995 ROAD Creek Road
r`-
Mountain City, TN 37683
Page 2

Permit NCG140232 Owner Facility Chandler ConcretelPiedmont Inc
Inspection Date 07/06/2016 Inspection Type Compliance Evaluation Reason for Visit Routine
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
❑ ❑ ❑
❑❑®❑
Comment According to Ken Wae erle no measurable storm event resultinq in discharge at the outfall
occured during work hours and/or while personnel were on site from September 17_, 2014 until
July 6, 2016 Most recent analytical monitoring was performed on September 17 2014 (PH B 2,
TSS 5 5 mg/L)
Newly constructed outfall #2 is not Included in the 2015 revision of the SWP3 Outfall #2 was
observed on the day of the inspection and no Analytical Monitoring has been documented from
this outfall
No vehicle maintenance is conducted at this location
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ®❑ ❑ ❑
# Were all outfalls observed during the inspection? ® ❑ ❑ ❑
# If the facility has representative outfatl status is it property documented by the Division? ❑ ❑ ® ❑
# Has the facility evaluated all illicit (non stormwater) discharges'? ® ❑ ❑ ❑
Comment The facility submitted a permit renewal request on June 30, 2016 A General. Permit has been
reissued with no changes for one year effective July 1, 2016
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? ❑ ❑ ❑
Comment According to Ken Waegerle, no measurable storm event resulting in discharge at the outfall
occured during work hours and/or while personnel were on site from September 17, 2014 until
July 6, 2016
Newly constructed outfall #2 is not included in the 2015 revision of the SWP3 Outfall #2 was
observed on the day of the inspection and no Qualitative Monitoring has been documented from
this location
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ® ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map? ® ❑ ❑ ❑
# Does the Plan snclude a Narrative Description of Practices ? ® ❑ ❑ ❑
# Does the Plan include a detailed site map includmg outfall locations and drainage areas? ❑ ®❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years? ® ❑ ❑ ❑
Page 3

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 0710612016 Inspection Type Compfaance Evaluation Reason for Visit Routine
Stormwater Pollution Prevention Plan
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan Include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan seclude a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan Include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan Include a Stormwater Facility Inspection Pmgram?
Has the Stormwater Pollution Prevention Plan been Implemented?
Yes No NA NE
® ❑ ❑ ❑
®❑ ❑ ❑
®❑❑❑
010 ❑ ❑
®❑❑❑
IN ❑ ❑ ❑
Is 11110
®❑❑❑
BE ❑ ❑ ❑
®❑ ❑ ❑
Comment Because the facility is remotely operated and no employees are stationed at this location on a_
dal!y basis employees are trained at plant #102 on Swing Rd in Greensboro Documentation
of the training Is maintained at plant #102„and It is noted in the plant #103 log _Becauuse the_
inspection was announced the facility contact was able to provide plant #103 documents
Durinq the August 27, 2015 NCDENRICity of Greensboro insciectlon, deficiencies for correction
were noted which recommended the addition of a berm and creation of an additional outfall #2
which would require same analytical sampling as outfall #1 During the Inspection, a berm and
second outfall were observed Ken Waegerle stated that the berm and outfall were
underconstructlon and would be included In the next revison of the SWP3 The current SWP3
and site map does not include the berm and outfall #2
• Complete dems 1, 2, and 3
■ Print your name and address on the reverse
so that we can return the card to you
■ Attach this card to the back of the mailpiece,
nr nn the front if ¢nary nnrmltc
1
Chandler Concrete Co , Inc
Attn Kenneth E Waegerle
1006 A Church Street
Burlington, NC 27216
1il
9590 9403 0921 5223 9930 24
7 err eta nIi imE,ar rTransfer from ServirO rape!/
7015 0640 0005'8164 4511
PS Form 3811, July 2015 PSN 7530 02 000 9053
,
A. 5 Slurs
X
B rRecety by (Pnn`d NAIT 1 C
D is d ryaddress different from Item 17 u
If YES enter delivery address below "'❑
3 Service Type
d OdtyMa l E"p„eSSO
❑ Adult Signature
❑ Adult signature Restricted Delivery
eg
0 Registered Mail Restricted
❑ Milled Malls
17Certif[ed Ma11 Resricted Delivery
Dolsvery
O Return for
t❑j
andiae
A S,. ure conRiTnation"m
Collect on Delivery Restricted Delivery
❑ Signature Confirmation
❑ Insured Mail
❑ Insured Mall Restricted Delivery
Restricted Delivery
Domestic Return Receipt `
Page 4

Lnel gy Mineral &
Land Resources
ENVIRONMENTAL OVAL ITY
July 8, 2016
CERTIFIED MAIL 7015 0640 0005 8164 4528
RETURN RECEIPT REQUESTED
Attn Ted Chandler
Chandler Concrete Co , Inc
1006 A Church Street
Burlington, NC 27216
Subject NOTICE OF DISCREPANCIES
NOD-2016-SP-0001
Permit# NCG140232
PAT McCRORY
C overnor
DONALD R VAN DER VAART
Sr(re ary
TRACY DAVIS
Dime ror
CERTIFIED MAIL 7015 0640 0005 8164 4511
RETURN RECEIPT REQUESTED
Attn Kenneth E Waegerle
Chandler Concrete Co, Inc
1006 A Church Street
Burlington, NC 27216
Chandler Concrete — Chimney Rock Rd Plant 9103
Guilford County
Dear Mr Chandler
On July 06, 2016 Jack Kitchen, Inspector with the NCDEQ (North Carolina Department of
Environmental Quality's) Multimedia Inspection Team, met with Ken Waegerle (Environmental Health
and Safety Manager) and James Edwards (Plant Manager) at the facility located at 114 N Chimney Rock
Road in Greensboro, to conduct an inspection to verify compliance with the facilities stormwater permit
requirements The inspection consists of review of the Stormwater Pollution Prevention Plan, training,
monitoring and spills records as well as observation of the general condition of the site, the outfalls and
any possible exposures to downstream stormwater
Chandler Concrete holds General Stormwater Permit NCG140232 to discharge stormwater from
industrial activity associated with Ready Mixed Concrete & like Activities under the National Pollutant
Discharge Elimination System (NPDES) The permit became effective July 01, 2011 and expires on
June 30, 2016
This facility is remotely operated by the Swing Rd Plant #102 No employees are based at the Chimney
Road Rd facility but supplies are brought to the site periodically and whenever the facility is used, trucks
pick-up and deliver concrete batches The truck wash is also used regularly So even though this plant is
remotely operated, it still has the same possible exposures as fully manned plants and therefore is not
exempt from bi-annual monitoring requirements
Stak of hotIhCdrohna I DwironmentalQoahly I Enugy Mmera1,)ndLandRetiourLcs
WmSIOn Sll< m R('g1011al OffuL 1450 Wines Mill Road SLu tr 300 I Winston Salem NC 11103
316 t' 61)800

Accordingly, the following observations and violations were noted during the NCDEQ Multimedia
Inspection and subsequent file review
Qualitative Monitoring
General Permit NCG140000, Part IV Section C requires the facility to conduct qualitative monitoring
twice per year following the established guidelines Inspection revealed that no qualitative monitoring
has been conducted at the facility since 09/17/2014 Monitoring must be completed twice annually and
records must be kept with the SPPP for a minimum of five (5) years
Analytical Monitorin
General Permit NCG140000, Part IV Section A requires the facility to conduct Analytical Monitoring
twice annually at each of the facilities stormwater outfalls The current general permit only requires
sampling for TSS (Total Suspended Solids) and pH semi-annually Monitoring must be completed twice
annually and records must be kept with the SPPP for a minimum of five (f) years
Required 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 violations will be addressed and should be sent to this
office at the letterhead address and include the following
Perform Qualitiative Monitoring twice annually Keep monitoring records in SPPP binder
2 Perform Analytical Monitoring twice annually as per permit requirements defined in Part IV,
Section A
Please direct your response and any questions regarding this letter to Glen White at [phone]
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures Inspection Report
cc File Copy Division of Energy, Mineral and Land Resources (WSRO)
Stalrof north Cat ohna I LnvitoninnentllQtiafity I Energy hhiteraland L-IndRLsourccs
Wanton Salem Regional Office I 450 Hanes Mill Road Su€tc 300 1 Winton Sakm. NC 27t03
3 56 776 9800

Ken Waeaerle
From Georgoulias, Bethany < bethany georgoulias@ncdenr gov>
Sent Tuesday July 05, 2016 9 24 AM
To Ken Waegerle
Subject NPDES NCG140000 General Permit renewed on July 1
Dear Permit Contact
io
t03
Thank you for submitting the permit renewal request (received on 06/30/2016 - 6 46pm) for Permit COC No
Fa146232 The NCG140000 General Permit has been reissued with no changes for one year, effective Friday, July 1,
20f6 As we stated in our letter from May 31", we will not issue you a new Certificate of Coverage until next year,
when the General Permit is revised However, the cover page of the permit has been revised to reflect new effective
dates
For your records, you may print a copy of the new General Permit cover page from our website (in the NPDES Industrial
SW section, General Permits) Or, you can go to this NCG14 Renewals -Map and search for your permit The "More Info"
link next the General Permit field in the pop-up box has been revised with the new permit You only need to print the
cover page that reflects the new dates for your records Please continue to use the same data monitoring forms (DMR)
As a reminder, if there has been a company ownership change, or if the Owner Affiliation needs to be updated, you
must submit the appropriate signed form to DEMLR's Stormwater Program Please contact us if you need one of those
forms or have any other questions
Sincerely,
The Stormwater Program
Bethany Georgouhas
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N C Department of Environmental Quality
919 807 6372 office
bethanv geor oulia5 c(nedenr gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N Salisbury Street, Raleigh, NC 27604 (location)
Website http //portal nedenr org/web/Ir/stormwater

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES - DIVISION OF WATER QUALITY
GENERAL PERMIT NO NCG140000
TO DISCHARGE STORMWATER AND/OR PROCESS WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Coverage under this General Permit is applicable to all owners or operators of establishments
classified as pi iinai ily engaged in ready -mixed concrete [Standard Industrial Classification
Code (SIC) 32731 and like activities deemed by DWQ to be sine lai in the process and/or the
exposure of raw materials, products, by-products, or waste materials
Dischai ges covered under this permit are
• Stormwater point source discharges (including discharges fi om on -site vehicle
maintenance areas), and
• Authorized process wastewater discharges
The following activities are specifically excluded from coverage undei this
Genei al Permit
• Disposal of wastewater not specifically designated in this permit
• Disposal of any concrete directly into stormwater conveyances, stoi in sewer outfalls,
wetlands, and/or into any waters of the state
In compliance with the provision of North Carolina General Statute 143-215 1, other lawful
standai ds and regulations promulgated and adopted by the North Carolina Environmental
Management Commission and the Federal Water Pollution Control Act, as amended, this permit
is hei eby issued to all owners or operators, hereafter permittees, which are covered by this
permit as evidenced by receipt of a Certificate of Coverage by the Environmental Management
Commission to allow the discharge of stormwater and pi ocess wastewater to the sui face waters
of North Carolina or separate storm sewer systems conveying stormwater to surface waters in
accordance with the terms and conditions set forth herein
The General Pet mit shall become effective on July 1, 2016
The Genei al Pei mit shall expit e at midnight on June 30, 2017
Signed this day June 30, 2016
Original Signed by Toby Vinson
for Ti acy E Davis, P E , CPM, Director
Division of Energy, Mineral, and Land Resources
By the Authority of the Environmental Management Commission

e •
s
K
C..
Enew, sera &
Land Resources
July 8, 2016
CERTIFIED MAIL 7015 0640 0005 8164 4528
RETURN RECEIPT REQUESTED
Attn Ted Chandler
Chandler Concrete Co, Inc
1006 A Church Street
Burlington, NC 27216
SubJect NOTICE OF DISCREPANCIES
PAT McCRORY
aawror
DONALD P. VAN DIM VAAWT
Seautwy
TRACY b.AVIS
CERTIFIED MAIL 7015 0640 0005 8164 4511
RETURN RECEIPT REQUESTED
Attu Kenneth E Waegerle
Chandler Concrete Co , Inc
1006 A Church Street
Burlington, NC 27216
NOD-2016-SP-0001
Permit# NCG140232
Chandler Concrete -- Chimney Rock Rd Plant #103
Guilford County
Dear Mr Chandler
On July 06, 2016 Jack Kitchen, Inspector with the NCDEQ (North Carolina Department of
Environmental Quality's) Multimedia Inspection Team, met with Ken Waegerle (Environmental Health
and Safety Manager) and James Edwards (Plant Manager) at the facility located at 114 N Chimney Rock
Road in Greensboro, to conduct an inspection to verify compliance with the facilities stormwater permit
requirements The inspection consists of review of the Stormwater Pollution Prevention Plan, training,
monitoring and spills records as well as observation of the general condition of the site, the outfalls and
any possible exposures to downstream stormwater
Chandler Concrete holds General Stormwater Permit NCO140232 to discharge stormwater from
mdustnal activity associated with Ready 1VMued Concrete & like Activities under the National Pollutant
Discharge Elimination System (NPDES) The permit became effective July 01, 2011 and expires on
June 30, 2016
This facility is remotely operated by the Swing Rd Plant #102 No employees are based at the Chimney
Road Rd facility but supplies are brought to the site periodically and whenever the facility is used, trucks
pick-up and deliver concrete batches The truck wash is also used regularly So even though this plant is
remotely operated, it still has the same possible exposures as fully manned plants and therefore is not
exempt from bi-annual monitoring requirements
Staft&NorehUroAna I Fn*e+nm=WQ *y I Snw"Nnerafand EandPesnumes
Wh "M-5a1eMRegkft6Qiilce I A501iWw WRoad,Suite30a I won-SaIenb3G 2703
356 776 9M

Accordingly, the following observations and violations were noted during the NCDEQ Multimedia
Inspection and subsequent file review
Ouahtahve Monitoring
General Permit NCO140000, Part IV ,Section C requires the facility to conduct qualitative monitoring
twice per year following the established guidelines Inspection revealed that no qualitative monitoring
has been conducted at the facility since 09/17/2014 Monitoring must be completed twice annually and
records must be kept with the SPPP for a minimum of five (5) years
Anal cal Mowtormiz
General Permit NCG140000, Part IV Section A requires the facility to conduct Analytical Monitoring
twice annually at each of the facilities stormwater outfalls The current general permit only requires
sampling for TSS (Total Suspended Solids) and pH semi-annually Monitoring must be completed twice
annually and records must be kept with the SPPP for a minimum of five (f) years
Reuuired Response
Accordingly, you are directed to respond to this letter in wnting within 30 calendar days of receipt of
this Notice Your response should outline how violations will be addressed and should be sent to this
office at the letterhead address and include the following
1 Perform Qualitative Monitoring twice annually Keep monitoring records in SPPP binder
2 Perform Analytical Monitoring twice annually as per permit requirements defined in Part IV,
Section A
Please direct your response and any questions regarding this letter to Glen White at [phone]
Sincerely,
Matthew E Gantt, P E
Regional. Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures Inspection Report
cc File Copy Division of Energy, Mineral and Land Resources (WSRO)
State of North Cwuliw I &Mmrmw=TQuallty 1 &w0yMirwalmcilAndffemmu
-sstemnrgta roi e f 4W TT& W Mffl?44 Sark aoa I v au -&kid WC X=
3M T&9saa

Compliance Inspection Report
Permit NCG140232 Effective 07/01/16 Expiration 06/30/17 Owner Chandler Concrete/Piedmont Inc
SOC Effective Expiration Facility Central Concrete Co Chimney Rock Road Plt #103
County Guilford 114 N Chimney Rock Rd
Region Winston Salem
Greensboro NC 27409
Contact Person Kenneth E Waegerle Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC
Secondary ORC(s)
On Site Representative(s)
Related Permits
Inspection Date 07/22/2016
Primary Inspector Glen White
Secondary Inspector(s)
Certification
Entry Time 10 OOAM Exit Time 11 OOAM
Phone
Phone [phone]
Reason for Inspection Routine Inspection Type Technical Assistance
Permit Inspection Type Ready Mix Concrete Stormwater/Wastewater Discharge COC
Facility Status ❑ Compliant Not Compliant
Question Areas
Storm Water
(See attachment summary)
Page 1

Permit NCG140232 Owner Facility Chandler ConcreteMiedmont Inc
Inspection Date 07/22/2016 Inspection Type Technical Assistance Reason for Visit Routine
Inspection Summary
(See Technical Assistance Letter)
Page 2

Permit NCG140232 Owner Facility Chandler ConcrelelPiedmonl Inc
Inspection Date 0712212016 Inspection Type Technical Assistance Reason for Visit Routire
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas
Yes No NA NE
❑ ■ ❑❑
❑ ❑ E ❑
Comment No monitoring oerformed since 2014 Site may recieve unannounced inspections to verifv "No
Flow" statement for the truck wash basin At the time of Inspection the basin appeared to have
been pumped down shortly before the visit There was an established waterline near the
elevation of the basin weir which would indicate a possible discharge New gravel at the outlet
obscured the ability to verify at that time
Outfall 2 - has had no monitonna althouah monitoring is required by the permit and there has
been obvious discharge including sand from the berm washing downstream Will need to verify
future compliance
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all oulfalls observed during the inspection? N ❑ ❑ ❑
# If the facility has representative outfall status is it properly documented by the Division'> ❑ 0 ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment Outfall 2 The berm is paoriv constructed It is made of sand and unstable and erosin
significantly Sand is the least viable material choice for a berms construction_ The berm needs
to be constructed of a stable material such as clay, concrete as alt or other stable material It
also needs to be stabilized permanently If its earthen, it needs to be vegetated
Improvements will be verified at the time of unannounced inspection
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? ❑ ❑ ❑
Comment According to Ken Waee erle the facility, has not received a measurable storm event since 2014
and the basin used to settle out sediment from truck was is pumped down to prevent a
discharge All recent gualitiative records are marked "no flow " This has not been verified
The second outfall has had significant discharge and is significantly eroding Verified at this site
visit
Unannounced inspections may be conducted in the future at this and other facilities to verify
compliance
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? E ❑ ❑ ❑
Page 3

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 07/2212016 Inspection Type Technical Assistance Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
# Does the Ptan include a General Location (USGS) map?
0
1111 ❑
# Does the Plan Include a Narrative Description of Practices ?
0
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0
❑ ❑ ❑
# Does the Plan mclude a list of significant spslls occurnng during the past 3 years?
i
■
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
E
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0
❑ ❑ ❑
# Does the Plan Include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Pan include a Preventative Maintenance and Good Housekeeping Plan?
0
[] ❑ ❑
# Does the facihty provide and document Employee Training?
0
❑ ❑ ❑
# Does the Pfan include a list of Responsible Party(s)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment SPPP is required to be maintained_onslte Please maintain the SPPP for each Chandler facility
at that individual facility, for maintaininq It and for review at any time
Unannounced Inspections may conducted at this and other facilities to verify compliance
Page 4

U5
City of Greensboro
L / North Carolina
September 14, 2015
Attn Ken Waegerle
Chandler Concrete Company, Inc
207 S Swing Road
Greensboro, NC 27410
RE Industrial Compliance Inspection
Inspection location Chandler Concrete Company
114 N Chimney Rock Road
SW Permit # NCG140232
Dear Mr Waegerle
On August 27, 2015 the City of Greensboro Stormwater Management Division completed an industrial
compliance inspection of Chandler Concrete Company Local regulations permit an inspection of
industrial facilities under authority granted by City of Greensboro Code of Ordinance Chapter 30, Article
12, Section 7 1 (C-5) This inspection consisted of two parts a review of the facility files/records and an
on -site facility inspection
The inspection was performed by Debbie Shoffner and Alex Tobergte with the City of Greensboro
(Stormwater Division) and Sue White and Glen White with NCDENR (Division of Energy, Mineral, and
Land Resources) The following deficiencieslobservations were noted during the inspection
Stormwater Pollution Prevention Plan/Spill Plan Review
Site Maps and SWP3
• No deficiencies observed
Spill Prevention and Response Plan
• Add spill kit and place it in an accessible location
Monitoring
• No deficiencies observed
Employee Training
• No deficiencies observed
PO 13oa 11 30 Gi(Pusboio VC 27102 3t 30 �,tN(�nsborn ncgoy !3IG) 171 Glt'1 (2189) M # 3,30930

Site lnspecbon
Preventative Maintenance/Good Housekeeping
• No deficiencies observed
Non-Stormwater Discharges
• Add berm or other diversion to direct flow to one area, creating an additional outfall on this site
This outfall will be designated as outfall #2 and will require the same analytical sampling as
outfall #1
It is recommended that Chandler Concrete Company take appropriate actions to correct the noted
deficiencies If you have any questions concerning this inspection please contact me at 336-373-2741
or Debbie Shoffner@greensboro-nc gov
Sincerely
/-" 641-A�
Debbie Shaffner, Water Quality Analyst
City of Greensboro Water Resources Department
cc Sue White, N C Dept of Environment and Natural Resources
Glen White, N C Dept of Environment and Natural Resources
Peter Schneider Water Quality Supervisor, City of Greensboro Stormwater
Alex Tobergte, Water Quality Specialist, City of Greensboro Stormwater
Industrial Inspection File

e
Compliance Inspection Repo
Permit NCG140232 Effective 07/01/11 Expiration 06/30/16 Owner Chandler ConcretelPledmontInc
SOC Effective Expiration Facility Central Concrete Co Chimney Rock Road Plt #103
County Guilford 114 N Chimney Rock Rd
Region Winston Salem
Greensboro NC 27409
Contact Person Kenneth E Waegerie Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC Certification Phone
Secondary ORC(s)
On Site Re prosentative(s)
Related Permits
Inspection Date 08/27/2015 Entry Time 08 30AM Exit Time 10 OOAM
Primary Inspector Glen White Phone [phone]
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Ready Mix Concrete StormwaterlWastewater Discharge COC
Facility Status 0 Compliant ❑ Not Compliant
Question Areas
E Storm Water
(See attachment summary)
Page 1

Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 08/2712015 Inspection Type Compliance Evaluation Reason for Visit Routine
Inspection Summary
Debbie Shoff ner and Alex Tobergte of the City of Greensboro Water Resources Department conducted a copliance
inspection of the subject facility of August 27 2015 Also in attendance were Sue White and Glen White for NCDENR
The inspection found the site to be in compliance with the permit and noted the following deficiencies for correction
1 Add a Spill kit and place it in an accessible location
2 Add berm or other diveersion to direct flow to one area creating an additional outfall on this site This outfall will be
designated as outfall #2 and will require the same analytical sampling as outfall #1
Page 2

Permit NCG140232 Owner Facility Chandler Concrete/Ptedmont Inc
Inspection Date 08/2712015 Inspection Type Compliance Evaluation Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes 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 ?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑ ❑
# Has the facility eva#uated 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 indude a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
IN
❑ ❑ ❑
Comment
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? 0 ❑ ❑ ❑
Comment
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? ❑ ■ ❑ ❑
Comment
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# if the facility has representative outfall status is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment
i
Page 3

ALIT;_WVWA
NCDENR
North Carolina Department of Environment and Natural Resources
Dlvts:on of Water Quality
Beverly Eaves Perdue
Charles Wakild, P E
Governor
Director
March 8, 2012
James Woody
Chandler Concrete Co Inc
— Plant 103
P 0 Box 131
Burlington, NC 27216
Subject
Compliance Evaluation Inspection
Chandler Concrete — Plant 103
NPDES Permit # NCG 140232
Guilford County
Dear Mr Woody
Dee Freeman
Secretary
On March 8, 2012 a Compliance Evaluation Inspection was performed by George Smith, of this office Mr
Forest Carter was present for the inspection The facility located at 114 N Chimney Rock Road, Greensboro
Records & Reports
The Stormwater Pollution Prevention Plan (SPPP) is kept in a 3-nng binder and is being implemented
• The Plan has a section containing forms that are used to document good housekeeping
• The qualitative forms are kept in the binder
• The analytical documentation is kept in the binder
Facility Site Review
Stormwater from process areas and the wastewater discharges dram into two in -line concrete basins and the
water from the second basin is recycled
There is one outfall, which periodically discharges from the 2nd basin There is a creek approximately 150-feet
from the outfall There are no indications of stream impacts from this concrete facility
A large portion of the facility has gravel cover and the back has some vegetative ground cover
The storage area for inert stockpiles is bermed and there is a forest of trees adjacent to the stockpiles
North Carolina Division of Water Quality Winston Salem Regional Office
Location 565 Waughtown St Winston Salem North Carolina 27107 One
Phone [phone] FAX [phone] NorthCarohna
Internet www ncwaterquality org naturally
An Equal Opportunity 4 Affirmative Action Employer

h
Compliance Evaluation Inspection
March 8, 2012
Page 2 of 2
Self -Monitoring Program
The analytical records show semi-annual monitoring for pH and TSS for the outfall The analytical results are
below the benchmark values
Rainfall amounts are recorded
Qualitative semi-momtonng is performed at one outfall
There is no vehicle maintenance area
Please make sure these are performed twice a year
The facility is well maintained, monitoring is performed, and the SPPP is being implemented Mr Carter is
doing a good job The inspection is satisfactory If you have any questions please contact George Smith or me at
[phone]
Sincerely,
W Corey Basinger
Regional Supervisor
Attachments
cc W SRO Files

it
Compliance Inspection Report
Permit NCG140232 Effective 07/01/11 Expiration 06/30/16 Owner Chandler Concrete/Piedmont Inc
SOC Effective Expiration Facility Central Concrete Co Chimney Rock Road
Plt #103
County Guilford 114 N Chimney Rock Rd
Region Winston-Salem
Greensboro NC 27409
Contact Person James J Woody Title Phone [phone]
Directions to Facility
System Classifications
Primary ORC Certification Phone
Secondary ORC(s)
On Site Representative(s)
Related Permits
Inspection Date 0310812012 Entry Time 08 30 AM Exit Time 09 00 AM
Primary Inspector George S Smith Phone [phone]
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Ready Mix Concrete Stormwater/Wastewater Discharge
COC
Facility Status ■ Compliant n Not Compliant
Question Areas
Storm Water
(See attachment summary)
Page 1

i
Permit NCG140232 Owner Facility Chandler Concrete/Piedmont Inc
Inspection Date 03/08/2012 Inspection Type Compliance Evaluation Reason for Visit Routine
Inspection Summary
Stormwater Pollution Prevention Plan
Yes No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
I
■ n
I
❑
n
# Does the Plan include a General Location (USGS) map?
■ r-1
I
n
n
# Does the Plan include a Narrative ❑escnptien of Practices ?
■ n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■ ❑
❑
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■ n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■ n
n
n
# Does the facility provide all necessary secondary containment?
■ n
n
n
# Does the Plan include a BMP summary?
■ n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■ n
n
n
# Does the facility provide and document Employee Training?
■ n
n
n
# Does the Plan Include a list of Responsible Party(s)?
■ n
n
n
# Is the Plan reviewed and updated annually?
■ n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■ n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■ n
n
n
Comment
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi annually?
■ n
In
n
Comment
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ n
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n n
■
n
Comment
Page 2

Stormwater Inspection
Date of Inspection M l-4. ,qa Inspector clwf e S'm' rh
Entry Time Exit Time ! 407
Permit Number NC (r NO W, Activity Rle'(4 - Ml i
Facility Name
Mailing Address _
City fJ tl r l i
A4AJ 1,r C tiev"ec-c C
PO 9.,( 131
ton
County CLI 1 / For
h 6 I I-r- 10,
State —V (, Zip
17�_16
■ a a ■ 1 ■ a a a ■ ■ ■ a ■ 1 a a a ■ ■ a a ■ ■ ■ ■ ■ 1 ■ ■ 1 a a ■ ■ ■ ■ a ■ 1 a ■ 1 ■ ■ a a ■ ■ ■ ■ ■ 1 1 ■ a ■ 1 ■ 1 ■ a a 1 . 1 ■ 1 a .... 1 . a ... a ■ a .. a ... a .
Facility Location j y) I mnc t ock j r_ya S n_k Ki c riiAr W A�,W, /at Chi.,,()
Facility Representative Frw-e T C ,--c-eI' Title Jldtt 01(y.61.1v
Telephone Number JU _) _ �1 7- i 7 1 5WI ►r c'
In PENN Montano■ a a a■■■ among OEM a a■■■ Mae a a a a. a.■ a■■■ a■ a a■ a■ a■■ a a■■ 1 Masao Ma■ a a■ 1 a■■ a■ a■■■ a
Implement SPPP
Analytical Monitoring _
Qualitative Monitoring L-< en I q � Z) Y-wvroi eynStWez r>'Y _
On -site Vehicle Maint A//P-
1 a■■ 1 a *Gems mom mom mango onea s a a a 1 moms1 moms Mason 0 mom a l memo moms a a a/■■■ a a a a 1■■■ BEEN Ga a l a a a■ a■■■■■ a a■
1Jan Ct 14EY
S2{ IVY /