HomeMy WebLinkAboutNCG140350_COMPLETE FILE - HISTORICAL_20170504STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V GCS I1V3'"
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑
YYYYMMDD
Division of Energy, Mineral, and Land Resources
Land Quality Section / Stormwater Program
National Pollutant Discharge Elimination System (NPDES)
Energy. Mineral a PERMIT OWNER AFFILIATION DESIGNATION FORM
Land Resources
ENViRONHENT AL OVALtIV (Individual Legally Responsible for Permit)
Use this form if there has been:
FOR AGENCY USE ONLY
Date Received
Year
Monti
Da
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or If the ownership of the facility has changed,
do NOT use this form. Instead, you must till out a Name -Ownership Change Form
and submit the completed form with all required documentation.
Wbat does "legally responsible individual' mean?
The person is either:
• the responsible corporate officer (for a corporation);
• the principle executive officer or ranking elected official (for a municipality, state, federal or other public
agency);
• the general partner or proprietor (for a partnership or sole proprietorship);
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible individual ("Owner Affiliation")
applies:
Individual Permit (or) Certificate of Coverage
11 N.1 C S N I C 1.G, Jfl5 L91
2) Facility Information:
Facility name: e
Company/Owner Organization:
Facility address:
Address
�✓�kc� arr it/`� �5 %
city state zip
To find the current legally responsible person associated with your permit, go to this website:
ltttp://de(l.nc.aovtabout/divisions/eneri y.-mineral-land-resources/eiiert;v-mineral-land-permits/stunnwater-iiroaraiii
and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed: f
Previous legally responsible individual: J0 �� f Y� il—
First MI Last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit: —�U , �•%1
First MI Last
Page I of 2
SWU-OWNERAFFQr23March2017
NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
gmA&A�
Title
n f Mailing Address
('eity State Zip
Telephone E-&&il Address
Fax Number
5) Reason for this change:
A result of: Employee or management change
Inappropriate or incorrect designation before
❑ Other
if other please explain:
The certification below must be completed and signed by the permit holder.
PER MITTEE CERTIFICATION:
J I, \k 1 , attest that this application for this change in Owner Affiliation
(person legally responsib a for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this form are not completed, this change may not be
processed.
DkA t\ A -i'-I
Signat� Date
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral, and band Resources
Stormwater Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please call (919) 707-9220 or visit the website at:
h":l/deg. nc. gov/about/divi sions/enemy-mineral -land-resources/stormwater
Page 2 of 2
swu-owtrt RAFFar23WO017
[Fwd: Talked With Robert Jones of F&R]
Subject: [Fwd: Talked With Robert Jones of F&R]
From: Myrl Nisely <myrl.nisely@ncmail.net>
Date: Thu, 22 Sep 2005 07:42:34 -0400
To: Ken Pickle <Ken.Pickle@ncmail.net>, Bethany Georgoulias<Bethany.Georgoulias@ncmail. net>
Ken/Bethany, as a followup on that conversation, Bob said the delay in getting back to us involved
getting data from surveyors at all the sites. They are surveying extensively in 6 inch elevations to provide
accurate topos of what's there. Bob then runs models of what various rainfalls do, and what can be
changed (BMPs) to improve things. Some model runs don't work out well, etc. Anyway, he will come '
with conceptual drawings of some ideas for the plants, with the idea that we will react to what we see,
maybe add suggestions from what we have seen elsewhere, and otherwise give a nod of approval on what
they propose. He didn't say it, but we can be sure that some ideas will have already been screened out as
too expensive.
MN
-------- Original Message--------
Subject:Talked With Robert Jones of F&R
Date:Thu, 22 Sep 2005 07:36:10 -0400
From:Myrl Nisely <myrl.nisely a,ncmai1.net>
To:Ken Pickle <Ken.Pickle o- ncmail.net>, Bethany Georgoulias
<Bethany.Georgoulias(cb,ncmail.net>, Ken Schuster <Ken.Schuster((bncmail.net>
Ken and Bethany,
I have set a tentative time of Wednesday., Oct._12,, at 9 AM in our
conference room to meet with F&R to go over Thomas Concrete plans. Will
this meet your schedules? If not, suggest another day right around that
time.
Bob had not responded for many days to an email I sent asking about a
meeting because he has been in MS (right abbreviation?) dealing with his
mom and dad, hurricane victims. They had retired to a small town across
the bay from Biloxi, MS. Folks are ok physically, but their place was
demolished, and dad's fishing boat was found 2.5 miles away, shattered.
They are all together now in Charlotte, NC, and see themselves as
fortunate. The experience of seeing what he saw there, both the worse,
evil in people and the best, altruistic people has left Bob shaken. Ee
was emotional talking about it.
We can't really imagine the upset and trauma these storms bring to
individual lives.
Myrl
Myrl A. Nisely <°))))><'
Environmental Chemist II
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: (919) 791-4200 or x4255
Fax: (919) 571-4718
myrl.niselyencmail.net ><((((O>
1 of 2 9/27/2005 10:04 AM
[Fwd: Talked With Robert Jones of F&R]
Myrl A. Nisely <°))))><
Environmental Chemist II
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: (919) 791-4200 or x4255
Fax: (919) 571-4718
myrl.nisely@ncmafl.net
2 of 2 9/27/2005 10:04 AM
SINCE
FROEHLING & ROBERTSON, INC
GEOTECHNICAL • ENVIRONMENTAL • MATERIALS
vXC ENGINEERS • LABORATORIES
"OVER ONE HUNDRED YEARS OF SERVICE"
2505 HUTCHISON McDONALD ROAD • CHARLOTTE, INC 28269
1881 Phone: (704) 596-2889 0 Fax: (704) 596-3784
Mr. Kenneth Schuster
North Carolina Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
Re: Thomas Concrete Project Status and Timelines
Dear Mr. Schuster:
0
July 12, 2005
`� GU S 7 w+, S i 5 L3 W—
. >r.,
As requested in your letter dated June 13, 2005 to Mr. John Holding of Thomas Concrete, we at
Frochling & Robertson, Inc. (F&R) are responding with the information which you have
requested. Prior to receipt of your letter, preliminary calculations and preliminary modeling
have been performed on the North West Street, Morrisville and the Wake Forest sites. The
accuracy of this data was determined to be inadequate due to significant topographical
modifications which have taken place at each of the sites modeled during their historical
operations. As of June 22, 2005, F&R was authorized to obtain the needed topographical data
needed which would accurately represent the present conditions at each of the sites. The
surveying activities should be completed by August 17, 2005 for the sites. The subsequent
estimated timeline for the site specific activities at each facility are as follows:
1131 N. West Street, Raleigh 4
• Complete surface water modeling by August 31, 2005.
• Prepare specifications for BMPs, topographic modifications
required, and appropriate treatment systems byES7e ie"r-20?
%0
• Due to the extensive planned changes to the prefabricated batch
mill at the site this schedule will be accelerated as rapidly as
possible but anticipate completion by March 1, 2006.
312 Plum Street, Durham
• Complete surface water modeling by September 30, 2005.
• Prepare specifications for BMPs, topographic modifications
required, and appropriate treatment systems by November 14-,-
2005.
• Completion of the onsite modifications are anticipated to be June
15, 2006 since significant subgrade improvements are anticipated
to avoid similar grade failures which contribute to infiltration and
uncontrolled runoff.
HEADCUARTERS: 3015 DUMBARTON ROAD • BOX 27524 • RICHMOND, VA 23261-7524
TELEPHONE (804) 264-2701 • FAX (804) 264-1202 • www.FandR.com
BRANCHES: ASHEVILLE, NC • BALTIMORE, MD • CHARLOTTE, NC • CHESAPEAKE, VA
CROZET, VA • FAYETTEVILLE, NC • FREDERICKSBURG, VA
GREENVILLE, SC • HICKORY, NC 9 RALEIGH, NC • ROANOKE, VA • STERLING, VA
SINCE
F&R .
ie:i
220 International Drive, Morrisville
• Complete surface water modeling by October 20, 2005.
• Prepare specifications for BMPs, topographic modifications
required, and appropriate treatment systems by[December_19,7
[2005..
• Complete site modifications and resume normal daily operations
by October 16, 2006.
2621 Teletec Plaza, Wake Forest
• Complete surface water modeling by November 21, 2005.
• Prepare specifications for BMPs, topographic modifications
required, and appropriate treatment systems by(Decembe`r I"9
11-- , -
• Complete site modifications and resume normal daily operations
by March 15, 2007.
140 Pamela Drive, Fuquay Varina
• Complete surface water modeling by December 30, 2005.
• Prepare specifications for BMPs, topographic modifications
required, and appropriate treatment systems by Februa
2{ LO6:.
• Complete site modifications and resume normal daily operations
by June 1, 2007.
i ?�
If there are any questions or we can be of further }assistance regarding the schedule or
implementation, please do not hesitate to call me at 704-596-2889.
Sincerely,
FROEHLING & ROBERTSON, INC.
Robert D. Jones, GC, EIT, MBA
Environmental Group Manager
Cc: Mr.Myrl Nisely
Environmental Chemist I1
Thomas Concrete proposed schedule
Subject-Ttiomas-Concre"te proposed.schedule
From: Ken Pickle <k ne Pickle
Date: Tue, 02 Aug 2005 17,21:51 -0400
To: Myrl Nisely <myrl.nisely@ncmail.net>
CC: Bethany Georgoulias <Bethany.geoi-goutias@ncmail.net>, Bradley Bennett
<bradley.bennett @ncmai l.net>
Myrl,
I've looked at the Thomas Concrete proposed schedule dated July 12, 2005. I have the
following observations and conclusions about their proposed schedule.
a) *All the physical surveys* at all five facilities will be complete by August 17,
2005. That date is almost at hand, and I think it's a reasonable time. See here
that the design engineer is obtaining a physical survey to support his subsequent
design work. I think that this has some bearing on our earlier discussion on the
availability of as -built drawings - - there should be no problem obtaining record
drawings at these sites for the already existing features. The engineer will then
add his site revisions, and submit them both for the AtC from us. The owner &
consultant & surveyor just need to know early that we will require them as part of
the AtC approval.
b) *Next, F&R will perform the talcs to size the required treatment systems* in
successive months starting with August 2005, and finishing in December 2005. They'll
essentially do a set of talcs each month for five months. I think this is a
leisurely, but reasonable schedule for the work involved in a design office.
Consider that when a design office completes a task frequently depends on when they
can make time in their already busy schedule.
c) *Next, blueline plans* will be produced between one month and two months after the
completed calcs at each site. The staggered start date of the talcs results in a
staggered schedule for completion of the blueline plans. Again, T think this is a
reasonable approach and time frame. I suspect F&R could compress their schedule if
they had to.
d) F&R's letter doesn't itemize the time required to *submit the plans for DWQ
approval* via the AtC, and it doesn't itemize the time required *to obtain bids from
contractors *for the construction work. I suspect that Thomas Concrete is a
ready -mixed concrete company only, and does not have construction forces of their
own.
e) The *construction period *proposed^for each site makes sense to me under specific
construction circumstances. First, if you imagine that one crew, or one small
contractor will be doing all the work at the five sites, you can imagine that Thomas
plans to complete one site, and then move to the next one, and so on. Hence the even
further staggered completion dates. Also, if you consider that the projects will be
completed in the sequence presented, and if you subtract out an optimistic 1 month
for the combined duration of DWQ review and issuance of the AtC, and the obtaining of
bids from contractors (or a single favored contractor), we see that the construction
duration ranges from 1 1/2 months at Fuquay-Varina to 4 1/2 months at Raleigh.
Without knowing the site conditions at these sites or the modifications proposed, my
first reaction is that it's all pretty reasonable. It also allows Thomas to stagger
their costs, which is usually a benefit to a business.
Also consider that the two longest duration construction periods might be seasonally
affected (I know I am.) I mean, consider that Raleigh will take 5 1/2 months
including DWQ approval, but that the work has to be accomplished in the winter.
Similarly, Wake Forest will take 5 months, including DWQ review time, again in the
winter when earthwork dependent construction is frequently delayed.
-s
f) I don't like the extended time frame. I think I understand Thomas' scheduling,
but I don't like it. Postponing an effective response to the control of wastewater
discharges until June 2007 just doesn't seem timely to me. Also, I assume it would
be possible for Thomas to engage multiple contractors and so pursue completion of two
or more projects concurrently. That would pull the staggered completion dates
backwards in time. Coupled with a compression of F&R's work schedule, I think they
1 of 2 8/4/2005 8:07 AM
Thomas Concrete proposed schedule
could pull completion at all sites back into 2006, rather than June 2007. I am not
sure of what our posture should be wrt their proposed schedule. I
Ken
2 of 2 8/4/2005 8:07 AM
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
June 13, 2005
Mr. John N. Holding
Thomas Concrete of Carolina, Inc.
P.O. Box 12544
Raleigh, NC 27605
Subject: Request for Project Status Updates and Timelines
Dear Mr. Holding:
Alan W. Klimek, P.E., Director
Division of Water Quality
JUN 15 2005
The Division requests an update on the status of work Froehling & Robertson, Inc.
is doing to establish Stormwater Pollution Prevention Plan (SP3) manuals and Best Management
Practices (BMPs) for each Thomas Concrete facility in the Raleigh Region. The facilities in our region
include Wake Forest, Durham, Morrisville, and the modifications at Raleigh West St. Please provide,
for each facility, within 20 days of receipt of this letter a timeline for submitting plans, specifications,
and supporting calculations for BMPs and any wastewater treatment systems (which include recycle
systems). Please include an estimated completion date for each site.
If you have questions or comments, please contact Mr. Myrl Nisely or me at the Raleigh Regional
Office, 919-571-4700 or myrl.nisely(Qncmai1.net
Sincerely,
,Y—
Kenneth Schuster
Raleigh Region Surface Water Supervisor
cc: Mr. Mark Terrell, P.E.
Froehling & Robertson, Inc.
2505 Hutchison -McDonald Rd.
Charlotte, NC 28269
Bethany Georgoulias, SWP Stormwater Permitting Unit
No hCarolina
�I �aturrr!!y
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 5714700 Customer Service
Internet! h2o.enr.state,nc.us 1628 Mail Service Center Raleigh, NC 27699-1629 FAX (919) 571-4718 1-877-623-6748
An Equal OpportunitylAtfirmative Action Employer — 50% Recyeledli0%a Post Consumer Paper
Draft of Thomas Status Letter
Subject: Draft of Thomas Status Letter
From: Myrl Nisely <myrl.nisely cr ncmail.net>
Date: Thu, 09 Jun 2005 l 1:35:52 -0400
To: Ken Schuster <Ken.Schuster@ncmai1.net>, Ken Pickle <Ken.Pickle@ncmail.net>, Bethany
Georgoulias <Bethany.Georgoulias@ncmail.net>, Bradley Bennett <Bradley,Bennett@ncmai1.net>
Attached is a draft for your consideration. Speaking with Bill Rice, the oversight of
all the work has been taken by Mark Terrell in Charlotte, and Bill also wonders about
the status of much of it. He has 5 SP3s semi -written and on hold until he gets the
details of BMPs to add. Some of them have the 12 month creation period expiring in
August, so he will likely contact me again after this letter goes out to ask about
what should be done.
Let me know your editorial changes, even if you have none.
Thanks,
Myrl
Myrl A. Nisely <•
Environmental Chemist II NC DENR - Div. Water Quality Raleigh Regional Office 1628
Mail Service Center Raleigh, NC 27699-1628 Telephone: (919) 571-4700, Extension 272
Fax: (919) 571-4718
mvrl.nisely@ncmail.net
F&RStatusRequest.doc Content -Type: application/msword
Content -Encoding: Base64
of 1 6/9/2005 12:55 PM
Recent correspondence with Myrl and Ken Schuster
Subject: Recent correspondence with Myrl and Ken Schuster
From: Ken Pickle <ken.pickle@nemail.net>
Date: Tue, 31 May 2005 11:26:49 -0400
To: Bethany Georgoulias<bethany.georgoulias@ncmail.net>, Myrl Nisely <myrl.nisely a ncmail.net>,
Bradley Bennett <bradley.bennett@nemail. net>, Ken Schuster <ken.schuster@ncmail.net>
Bethany,
Thanks for sending me that recent correspondence on NCG14. I have comments on four
topics.
a) Thomas Concrete - No comment from KBP.
b) AtC plans review for existing/proposed BMPs at existing permitted facilities - I
remember that we discussed several options around this topic, but I don't have a clear
recollection of whether we decided to 'let RRO to request the plans and review them, or
whether to let RRO to request the plans and SPU review them, or whether to not request
plans at all for existing permittees.
c) Plans review as part of the first permit application for new facilities - Just a
comment - As we all know, I've been bragging about the talcs submitted to me - ONCE.
It seems reasonable to make permit issuance dependent on this sort of AtC review for a
new facility. I'm hopeful that we will be successful in getting large numbers of
first time applicants to submit similar engineering talcs in support of their
applications. However, I don't think we can expect any significant success in getting
existing sites to submit similar talcs on their already existing treatment
facilities. I would like to be proved wrong on this point.
d) Just to clarify my thinking on the question of how long we allow for the
development of StormwaterPPPs. I see the question in terms of the facility's permit
status. Note that the NCG14 provisions are similar to several other of the NCGs.
i. PERMIT STATUS - For a newly constructed industrial facility, seeking its first
stormwater discharge permit, a StormwaterPPP must be in place on day 1. This is
clearly provided for in the permit, and I don't think we need further discussion on
this category of facility. (Except possibly on the point of what if they don't have
the required StormwaterPPP at the time of the application? Do we withhold the
permit? Or, do we issue the permit, and immediately cite them for non-compliance?
But that's not the issue under discussion now.)
ii. PERMIT STATUS - As suggested by Ken Schuster, for an industrial facility existing
at the time of the creation of the first round of industrial permits, and seeking
coverage under NCG14, the facility has 12 months to develop and implement the
StormwaterPPP. It seems to me that this would clearly apply back in the day. The
only discussion that would seem relevant now is to note that, of course, the provision
of the permit is moot for all facilities in the sense that the time has expired, and.
there are no more facilities in this category today. Again, this doesn't require
further discussion, except to note that the provision has been carried on to
subsequent re -issues of the NCGs, presumably for some purpose. (Although, the comment
from Ken S. essentially suggests that perhaps we've carried it forward by mistake.)
iii. PERMIT STATUS - For existing facilities applying for the first time today for an
already established NCG14. NCG14 is not new; the facility is not new_ So, it must be
that the facility has been in violation of the CWA, and in violation of the NPDES
program requirements in that it has been discharging stormwater (and wastewater)
without a permit. Note, however, that the facility has not been in violation of its
permit, since it hasn't had a permit. So, it has not been in violation of the permit
requirement to have a StormwaterPPP, nor in violation of any permit schedule as to
when to have this StormwaterPPP. I see two paths from here.
---- A ---- If we assume the permit language is not a mistake, then typically we would
1 of 2 6/7/2005 2:36 PM
Recent correspondence with Myrl and Ken Schuster
issue a permit to a ready -mixed facility that is in violation of the CWA for not
having a permit, we would give them 12 months to develop and implement a
StormwaterPPP, and we would essentially be doing what Ken S. objected to, namely
"authorizing" the continued discharge of untreated stormwater for 12 months. We would
be authorizing the discharge in the sense that we know about it, and yet we don't
enforce against the facility because the permit doesn't require any implementation
until 12 months have passed. On the one hand, this is a good thing, because we have
pulled another facility in under the permitting program. But, from Ken S's
perspective, one of his missions as a regional office is to improve water quality by
enforcing against those discharging untreated stormwater - and we've just issued a
permit that prevents him from doing that (at least for the first 12 months.)
---- B --- If we assume that the permit language has been mistakenly carried forward for
several re -issues of this NCG (and many others, too), then are we really in a DWQ
policy/strategy mess? It seems to me that the permit language stands even if it has
been carried forward mistakenly, and the permittee can argue that he has no obligation
until 12 months have passed. So, in answer to Ken S's suspicion that the language has
been carried forward by mistake, it doesn't matter. Either way, whether by mistake or
not, that's the way the permit is written. I don't see any wiggle room for us on
interpretation.
And finally, I wonder if there is a path here for enforcement action with regard to
the difference between NCG14 stormwater and NCG14 wastewater. Note that: the
requirements of the StormwaterPPP (including the 12 month schedule) listed in the
permit mimic the language contained in the other storwater-only NCGs; the language
seems specific for stormwater discharges and no special language is added to include
wastewaters. Could we argue that the StormwaterPPP requirements do not appLY to the
wastewater discharqes? And that the 1 month implementa ion perio oes not apply to
the wastewater discharges?' -And that Ken S. can enforce on wastewater discharges in
excess of limits on day 1? I think so. It's true that we have captured
stormwater and wastewater under this one permit. But, it is also true that the permit
distinguishes clearly between requirements on stormwater and requirements on
wastewater, and that the title of the document under consideration is specifically the
StormwaterPPP, just like in all the other stormwater-only NCGs. I think we could
adopt this posture and get to where Ken S. wants to be on enforcement - at least for
the wastewater discharges. He would have to allow 12 months of continuing untreated
stormwater discharges, but he could enforce on day 1 for the wastewater discharges.
More productively, and more likely, he could use this posture to leverage quicker,
better response from a newly permitted facility on implementation of stormwater BMPs.
Comments?
Ken
2 of 2 6/7/2005 2:36 PM
Re: Thomas Concrete Fallow -up
Subject: Re: Thomas Concrete Follow-up
From: Bradley Bennett <bradley. bennett a ncmai1.net>
Date: Tue, 31 May 2005 11:19:29 -0400
To: Ken Schuster <ken.schuster@ncmai1.net>
CC: Bethany Georgoulias<bethany.georgoulias@ncmail.net>, Myrl Nisely <myrl.nisely@nemail.net>
rcm
Maybe we can talk tomorrow sometime during the Enforcement Conference. The 12 months
is in the general permit. This is probably something we should look at for reissuance
of any of our GPs since they all have the same 12 month window for existing
facilities. There probably should be a window of time to allow them to get into
compliance, but maybe 12 months is too much. This is a carry over from the original
permits that were issued. I'm not sure if we could administratively change that time
frame in a letter. I guess there would be a higher potential in the case of
facilities that get NOVs from us. Try and catch us tomorrow and we can discuss.
BB
Ken Schuster wrote:
Bethany, I'd like to resolve how we are interpreting the 12 month compliance
condition in the permit before we send Thomas a letter.
Bethany Georgoulias wrote:
Ken,
I think your concerns regarding the 12 month compliance period are legitimate,
and this was an important reason for our rationale regarding a follow-up letter
from the Region (with a time -line to submit plans) soon after issuing the COC to
an existing facility. Bradley is out of the office the rest of the week, so
I'll defer further discussions on the topic until he returns. Does the RRO feel
a follow-up letter for Thomas is not the way to go anymore? Thanks for the
comments,
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
Ken Schuster wrote:
Bethany, several months ago the Stormwater group and the RRO considered
requiring A to C submittal/approval for any new BMPs at the ready mixed
concrete plants. At that time it seemed to be the consensus that we would
not put that burden on the concrete folks and on you folks in the Archdale
Building. Recently however, it does seem like the Stormwater unint has been
asking the consultants for their engineered BMP designs/plans. You may -not
be requiring the full application needed for an A to C, but you are asking
for some basic information to show that they have engineered designs. I
think this is great and is the way to go. You had asked about the
compliance timeline and Myrl mentioned the 12 month compliance condition in
the permit. Myrl and I took a look at Part III. Section A: Compliance and
Liability. "Existing faciliites" are required to develop and implement the
SP3 within 12 months of the effective date of the initial certificat of
coverage. "Proposed facilities" must implement the sp3 prior to the
beginning of discharge. I would guess that this condition was put in the
initial 1994/95 permit to allow adequate time for all those facilities that
of') 5/31/2005 11:25 AM
Re: Thomas Concrete Follow-up
did not yet have certificate of coverage. It seems the intent was not for the
condition to be carried forward in subsequent permits, otherwise those plants
that delay in getting the coc would have a year to implement the plan, and
condition #9 of the spa requirements is "implementation". Condition #9
includes the following: "activities taken to implement BMPs associated with
the industiral activities, including vehicle maintenance activities". Thus,
it appears that existing facilities that are just now receiving cocs have
time, a year, to implement BMPs. I don't think this was the intent of the
compliance schedule in Part ITT. Section A. Otherwise, it would imply that
those existing facilities that do not yet have cocs do not have to meet
compliance with the SP3, including BMPs, and don't have to until a year after
receiving the coc. Bradley, can you help us with what the permit says and
what the intent was (if different)? Obviously, we want to see compliance
asap and when we observe a regulated entity in non-compliance we don't
informally allow them time to come into compliance. They simply remain in
non-compliance that much longer the longer it takes to remedy
non-compliance. We do negotiate formal special orders of agreement or agree
to settlement agreements in certain situations. Ken.
Bethany Georgoulias wrote:
Myrl,
I just talked with Bradley, and we both thought we'd all discussed the
next step of a follow-up letter from the Regional Office establishing a
time line for submitting plans, especially since the RO was in the best
position to determine the most reasonable time frame (dependent in part
upon their SP3 progress). I know the rapport has been a good one with
F&R, and I'm so glad to see it continue, but we feel like there should be
something in writing to document this next expectation of the Permittee.
Does this sound reasonable? We're certainly open to discussing it some
more.
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
Myrl Nisely wrote:
Maybe I am confused, too! The last written commentary I have covers
recons with Bill at Morrisville and Angier Ave. But they say nothing
about submitting plans or timelines. As for new COCs for the two or
three facilities that had no permits, I believe the permit itself
allows them 12 months to put together the SP3. Verbally I have asked
Bill to speed that up and get stuff to us as early as possible, but
there have been no specific times set. I am working under the
assumption that F&R will move forward with reasonable speed. They have
quite a bit to do to study each site and work out what BMPs should be
done, getting Thomas approval, etc. I vote to leave them alone. What
do you think?
Bethany Georgoulias wrote:
No problem!
For Thomas, I thought the RRO was going to follow up with a letter
regarding this issue after the COC was issued that would also set a
time table for submission of those plans, calcs, etc. Is there no
plan for a follow-up letter? Maybe we should discuss with Bradley
2 of 3 5/31/2005 1 1:25 AM
Re: Thomas Concrete Follow-up
and Ken Schuster ... I think I may have been confused. -BG
Myrl Nisely wrote:
Thanks for checking with Sarah.
As far as I know, Bill Rice is working on the SP3s and plans for
each site, so he will submit things when F&R and Thomas agree
they are ready. Did DWQ place any time constraint on when they
should be done?
MN
Bethany Georgoulias wrote:
Hi Myrl,
I don't have this application --not sure about the others. Aisha
is overseas until mid -June, but if it came in our shop, Sarah
might have seen it. We'll check.
By the way, what is the status of follow-up to Thomas Concrete's
Wake Forest plant regarding plan submittal for a future AtC, etc.?
cheers,
BG
Bradley Bennett <bradley.bennett(a,ncmail.net>
Division of Water Quality
Stormwater Permitting Unit
3 of 5/31/2005 11:25 AM
Re: Thomas Concrete Follow-up
Subject: Re: Thomas Concrete Follow-up
From: Bethany Georgoulias<bethany.georgoulias@ncmail.net>
Date: Mon, 23 May 2005 09:11:08 -0400
To: Myrl Nisely <myrl.nisely@ncmai1.net>
CC: Ken Schuster <Ken.Schuster@ncmail.net>, Bradley Bennett <bradley.bennett@ncmai 1. net>
Myrl,
I just talked with Bradley, and we both thought we'd all discussed the next step of a
follow-up letter from the Regional Office establishing a time line for submitting
plans, especially since the RO was in the best position to determine the most
reasonable time frame (dependent in part upon their S23 progress). I know the rapport
has been a good one with F&R, and I'm so glad to see it continue, but we feel like
there should be something in writing to document this next expectation of the
Permittee. Does this sound reasonable? We're certainly open to discussing it some
more.
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
Myrl Nisely wrote:
Maybe I am confused, too! The last written commentary I have covers recons with
Bill at Morrisville and Angier Ave. But they say nothing about submitting plans or
time lines. As for new COCs for the two or three facilities that had no permits, I
believe the permit itself allows them 12 months to put together the SP3. Verbally
I have asked Bill to speed that up and get stuff to us as early as possible, but
there have been no specific times set. I am working under the assumption that F&R
will move forward with reasonable speed. They have quite a bit to do to study each
site and work out what BMPs should be done, getting Thomas approval, etc. I vote
to leave them alone. what do you think?
Bethany Georgoulias wrote:
No problem!
For Thomas, I thought the RRO was going to follow up with a letter regarding
this issue after the COC was issued that would also set a time table for
submission of those plans, calcs, etc. Is there no plan for a follow-up
letter? Maybe we should discuss with Bradley and Ken Schuster...I think I may
have been confused. -BG
Myrl Nisely wrote:
Thanks for checking with Sarah.
As far as I know, Bill Rice is working on the SP3s and plans for each site,
so he will submit things when F&R and Thomas agree they are ready. Did DWQ
place any time constraint on when they should be done?
MN
Bethany Georgoulias wrote:
Hi Myrl,
I don't have this application --not sure about the others. Aisha
is overseas until mid -June, but if it came in our shop, Sarah
l of 2 5/23/2005 1:46 PM
Re: Thomas Concrete Follow-up
might have seen it. We'll check.
By the way, what is the status of follow-up to Thomas Concrete's
Wake Forest plant regarding plan submittal for a future AtC, etc
cheers,
BG
2 of 2 5/23/2005 1:46 PM
RE: Thomas Concrete - Wake Forest Plant
Subject: RE: Thomas Concrete - Wake Forest Plant
From: "William Rice" <WRice@FandR.com>
Date: Mon, 25 Apr 2005 14:04:1.3 -0400
To: "Bethany Georgoulias"<bethany.georgoulias@ncmail.net>
Hi Bethany,
Yes please. My fax number is 919-828-5751.
Thanks,
Bill
------Original Message -----
From: Bethany Georgoulias [mailto:bethany.georgoulias@ncmail.net]
Sent: Monday, April 25, 2005 2:07 PM
TO: William Rice
Cc: Aisha Lau; myrl nisely
Subject: Re: Thomas Concrete - Wake Forest Plant
Hi Bill,
I wanted to let you know that the COC was issued for the Thomas
Concrete -Wake Forest Plant last week. It is COC No. NCG140350 and was
effective April 22, 2005. Would you like me to fax a copy of the COC
and cover letter to you? What is your fax number?
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
William Rice wrote:
Hi Bethany,
As I mentioned in my phone message to you, I would like to request an
advisement of the numbers and dates of the new NCG140000 permit
certifications for the Wake Forest and Fuquay-Varina Thomas Concrete
Plant sites. Additionally, z would also like to request copies of
these permits certifications for inclusion into the appendices of
their respective Stormwater Pollution Prevention Plans.
Thank you,
Bill Rice
Environmental Planning Manager
Froehling & Robertson, Inc.
310 Hubert Street
Raleigh, NC 27603
1 of 2 4/25/2GO5 2:35 PM
Michael F. Easlev, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek. P. E. Director
Division of Water Qualitv
Coleen H. Sullins, Deputy Director
Division of Water Quality
April 25, 2005
To: Bill Rice, Froehling & Robertson, Inc.
Fax: (919) 828-5751
From: Bethany Georgoulias
Phone: (919) 733-5083 ext. 529
Fax: (919) 733-9612
4 pages, including cover sheet.
Comments:
Attached is a copy of the COC and cover letter sent out to Thomas Concrete for the Wake
Forest Plant (COC No. NCG140350)
o cerely,
c ,
Bethany Georgoulias
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-7015
AXA
1 cb0-17:
Customer Service
1-877-623-6748
dF WA TF9
Q
co
G
7 �
April 22, 2005
Mr. John Holding, President
Thomas Concrete
611 Tucker Street
Raleigh, NC 27603
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: General Permit No. NCG140000
Thomas Concrete —Wake Forest Plant
COC No. NCG140350
Wake County
Dear Mr- Holding:
In accordance with your application for a discharge permit received on December 28,
.2005 and additiolial information received February 14, 2005, we are forwarding herewith the
subject certificate of coverage to discharge under the subject state — NPDES general permit.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215
and the Memorandum of Agreement between North Carolina.and the US Environmental
Protection Agency dated May 9, 1994 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act or any other federal or local governmental permit that
may be required.
If you have any questions concerning this permit, please contact Bethany Georgoulias at
telephone number (919) 733-5083 ext. 529.
Sincerely,
Copy - Original signed by
Bradley Bennett for
Alan W. Klimek, P.E.
cc: Raleigh Regional Office
Central Files
Stormwater Permitting Unit Files
NorthCarolina
Naturallb,
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733.7015 Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-977-623-6748
An Equal OpportunIVAffirmaWe Action Employer — 50% Recydedl1011. Post Consumer Paper
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG140000
CERTIFICATE OF COVERAGE No. NCG140350
STORMWATER AND PROCESS WASTEWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Thomas Concrete
is hereby authorized operate a process wastewater treatment system, and is hereby authorized to
discharge process wastewater and stormwater from a facility located at
Thomas Concrete —Wake Forest Plant
2621 Teletec Plaza
Wake Forest
Wake County
to receiving waters designated as an unnamed tributary (UT) to the Neuse River, a class WS-IV
NSW water in the Neuse River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, H, III, IV, V, and VI of General Permit
No. NCG140000 as attached.
This certificate of coverage shall become effective April 22, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 22, 2005.
Copy _ Original SIget d by
Bradley Berm
for Alan W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission
LOCATION MAP:
Latitude: 35°55'16" NCG 140350
Longitude: 78°32'51" Facility;`
County: Wake, NC Thomas Concrete — Location
Stream Class: WS-IV NSW Wake Forest Plant
Receiving Stream: UT to Neuse River
Sub -basin: 03-04-02 (Neuse River Basin) [Ji%�tli !CALF 1ad,00tf
o�0 W A rF9pG
U? r
y
Apri 122, 2005
Mr. John Holding, President
Thomas Concrete
611 Tucker Street
Raleigh, NC 27603
Michael F. Easley. Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: General Permit No. NCG140000
Thomas Concrete —Wake Forest Plant
COC No. NCG140350
Wake County
Dear Mr. Holding:
In accordance with your application for a discharge permit received on December 28,
2005 and additional information received February 14, 2005, we are forwarding herewith the
subject certificate of coverage to discharge under the subject state — NPDES general permit.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215
and the Memorandum of Agreement between North Carolina and the US Environmental
Protection Agency dated May 9, 1994 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act or any other federal or local governmental permit that
may be required.
If you have any questions concerning this permit, please contact Bethany Georgoulias at
telephone number (919) 733-5083 ext. 529.
Sincerely,
Copy - Original signed by
Bradley Bennett for
Alan W. Klimek, P.E.
cc: Raleigh Regional Office
Central Files
Stormwater Permitting Unit Files
No'AbCarolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service
Intemet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Retycled/10% Post Consumer Paper
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ENERAL PERMIT NO. NCG140000
CERTIFICATE OF COVERAGE No. NCG140350
STORMWATER AND PROCESS WASTEWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Thomas Concrete
is hereby authorized operate a process wastewater treatment system, and is hereby authorized to
discharge process wastewater and stormwater from a facility located at
Thomas Concrete —Wake Forest Plant
2621 Tetetec Plaza
Wake Forest
Wake County
to receiving waters designated as an unnamed tributary (UT) to the Neuse River, a class WS-IV
NSW water in the Neuse River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts I,11, III, IV, V, and VI of General Permit
No. NCG140000 as attached.
This certificate of coverage shall become effective April 22, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 22, 2005.
Original signed by
copy
ep Bradley Bennett
for Alan W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission
1,
Al
LOCATION MAP:
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A
[j" , `=�'1� -'t' e��'�e� � ��r{ - ".��/f{�i�l � - - ��~F` y�l -�` i � ;a' �: i � �, +��'�`�� f l '�. j e
YZ
V, 11 Thomas Concrete— L "z)
Wake Forest Plant
4 1�
10
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Latitude: 35'55'16"
N CG 140350 Facility
Longitude: 78'32'51"
County: Wake, NC Thomas Concrete
Location
Stream Class: WS-IV NSW Wake Forest Plant
Receiving Stream: UT to Neuse River
Sub -basin: 03-04-02 (Neuse River Basin)
January 25, 2005
Mr. William T. Rice II
Froehling & Roberston, Inc.
310 Hubert Street
Raleigh, NC 27603
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: General Permit NOI
Permit NCG140000
COC No. NCG 140350
Thomas Concrete - Wake Forest Plant
The Division of Water Quality has reviewed your request for a new NPDES General Permit
received on December 28, 2004. We are requesting additional information (in this case, a
revised application) to address the following items:
❑ Application must be signed by a company official, per NCAC 15A 02H .106.
❑ Please provide more information regarding "purged material and water from the mix plant
[that] is dropped into a truck and driven to the first settling pond cell." (Question 13.) In
addition to stormwater discharge, General Stormwater Permit NCG140000 covers (1) vehicle
and equipment cleaning, (2) recycle system overflow, (3) raw material stockpile wetting, and
(4) mixing drum washout discharges; however, whether'mix plant purge material and water'
falls into one of these categories is not clear. Please refer to NCG140000 (accessible from
our website: http/lh2o.enr.state.nc.us su/Forms Documents. htm#stormwaterGP) for the
specific types of discharge covered by the general permit.
The original application is attached. Please return the revised application and information
requested above by March 1, 2005 so that we may continue processing your request. To avoid
confusion regarding payment for this NOI application and to preserve the assigned permit,
number in our tracking system, we are treating this as an additional information request, rather
than a return of your application package.
If you have any questions, please contact Bethany Georgoulias at (919) 733-5083 extension
529.
rel jJ
Bet ny A. eorgouTias
Environmental Engineer
cc: Stormwater Permitting Unit Files
Raleigh Regional Office
NZhCarolina
NatitrallIj
]North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-977-623-6748
An Equal OpportunitytAffirmative Action Employer — 501Y. Recycled/10% Post Consumer Paper
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
Division of Environmental Health
Public Water Supply Section
Michael F. Easley, Govemor
WiMam G. Ross Jr., Secretary
Terry L Pierce, Director
Jessica G. Was, Section Chief
MEMORANDUM
TO: Bethany Georgoulis
Storm Water Permitting Unit
FROM: Jessica G. Miles, P.E., C.P.M.
�4,
Section Chief
Public Water Supply Section
DATE: April 4, 2005
NCDENR
SUBJECT: Draft National Pollutant Discharge �` w �LE
Elimination System Permit NCG140350 D
Thomas Concrete -Wake Forest Plant APR 1 8 no
2621 Teletec Plaza
UALITy
Wake County WETUJY SM sroRAt qTERgR,gNCfj
Reference is made to the above mentioned Draft National Pollutant Discharge' Elimination System
Permit. Upon review of this permit application, it appears that no adverse effect on water quality will occur
to the existing public water supply intakes.
We concur with the issuance of this permit provided this facility is operated and maintained properly,
the stated effluent limits are met, prior to discharge; and the discharge does not contravene the designated
water quality standards.
If we can be of further assistance, please contact Michael L. Douglas, P.E. at 919-571-4700.
JGNVMLD/pja
1634 Mail Service Center. Raleigh, North Carolina 27699-1634 • Telephone: 919-733-2321
t{1,.:_ TJ-... nln �f1S I7.TI ► � .. 1. rT__.. Q__. nin lie lr1.f ♦ L...__,.a. 6a._.1!_-r.,.7�6:_�.-._x._.....,, ..-....!
`J�f Q )� APR D Michael F. Easley, Governor
0 RPG R Z 8 20I}� William G. Ross Jr.. Secretary
'North Carolina Department of Environment and Natural Resources
6S- /;TES Q Alan W. K]imek, P. E. Director
STOR I TY Division of Water Quality
TERO &%NC�t Coleen H. Sullins, Deputy Director
Division of Water Quality
March 22, 2005
Memorandum
To: Michael Douglas, Regional Water Supply Supervisor
Department of Environmental Health (DEH), Raleigh Regional Office (RRO)
From: Bethany Georgoulias, Stormwater Permitting Unit
Subject: Review of the discharge location for the following:
Thomas Concrete — Wake Forest Plant
2621 Teletec Plaza
Wake Forest, NC 27587
Wake County
NCG140350
'ALA ;tit
Please indicate your agency's position on the ready -mix concrete facility listed above. Attached is a copy of the
Notice of Intent (NOI) and staff review summary for this facility. We cannot issue the permit without your
concurrence_ Please return this form at your earliest convenience.
RESPONSE:
This agency has reviewed the draft permit and determined that the proposed discharge will not be
sufficiently close to any existing or known proposed public water supply intake so as to create an
adverse effect on water quality. We concur with the issuance of this permit, provided the facility
is operated and maintained properly, the stated effluent limits are met prior to discharge, and the
discharge does not contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below (or attached):
Signed J Date: 5 .3 O S
cc: Stormwater Permitting Unit Files
Attachments
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-7015
NCl3Eh'�rt
Customer Service
1-877-623-6748
SINCE FROEHLING & ROBERTSON, INC
�Q GEOTECHNICAL a ENVIRONMENTAL a MATERIALS ENGINEERS • LABORATORIES
�( 310 Hubert Street, Raleigh, NC 27603
0
1881
December 23, 2004
Stormwater and General Permits Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Submittal of Notice of Intent NCG140000 NPDES Application Package for
Thomas Concrete, Wake Forest Plant Facility
Dear Stormwater and General Permits Unit Representative:
Please find enclosed the above cited application package. Should you have any
questions or concerns, please do not hesitate to call me. I may be reached at the
numbers shown below, or contacted via e-mail at wrice(o-)-fandr.com.
Sincerely,
William T. Rice 11
Environmental Planning Manager
Telephone (919) 828-3441, Ext. 334
Facsimile (919) 828-5751
D
DEC $ 2004
DENR - WATER QUALITY
Wetlands & Stormwater Branch
Qt7 00
APR 1 S 2005
OENR - WATER QUALITY
WEff MOS AND STORAfWATER BRANCH
Contents in this Application Package
1). NCG140000 N.O.I. Application
2). Attached Page for Response to Question 13 of the NCG140000 N.O.I.
Application
3). A check for the amount of $80.00 written to the Stormwater General
Permits Unit of the Division of Water Quality
4). Directions to the subject facility
5). A U.S.G.S. Topographic map clearly showing the subject facility
6). An aerial photograph of the subject site
i). A site diagram showing facility runoff characteristics and receiving waters
Elm
EEC 2 8 2Ub,
DENR - WATER QUALITY
Wetlands & Stormwater Branch
ANIEW
NCDENR
CwiY.]F �� �h� N+t11�r Pf60.��C�b
Divislon of Water Quality 1 Water Quality Section
1atio11a1 I'nHutant Discharge Elimination System
NCG 140000
FOR AGENCY USE ONLY
Dalp Rernnrd
t"ntr
Alon[L
Day
0Conrffca10
of Cowr
L�
Check 4 I Aj—
�^ .po
}35rmit Ass Ned to
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG140000:
STORMWATER AND PROCESS WASTEWATER DISCHARGES associated with activities classified as:
SIC 3273 Ready I.,iixed Concrete
' Standard Industrial Classification Code
(Please print or type)
1) Mailing address' of ownerloperator:
Name Thomas Concrete CIO Mr. John Holding, President
Street Address -611 Tucker Street ^
City
Telephone No.
_Raleyh—__—__—__ _T State NC—__ ZIP Code—__27603 _—_—
_919:B32 94------------- Fax: »--83_4_-6_9J_1__
' Adfcss to whi,h ar permit eirr_spcn&ncs_• irAll be maaed
2) 2) Location of facility producing discharge:
Facility Name -Thomas Concrete Wake Forest Plant
t=acility Contact Mr. Brian Westfall Plant Manager—__--__—__
Street Address _ 2621 Teletec Plaza —__ ___—_—
City -Wake Forest—_—_—__—_—__— State _ NC -_ ZIP Code 27587 —__—_—
County Wake _ __
Telephone No. 919 a62=19�9-- ------ Fax: 919--- --T-562_-09 ---
3) Physical Location Information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). From DWQ Raleigh. go west on Barrett Dr. to Haworth Dr. (eroceed 0.1
mile). Turn right onto Six Forks Rd (proceed 0.3 mile). Merge onto 1-440 EIUS-1 N (proceed 2 miles). Merqe onto Capitol Bld1US-1Nviavia
Exit II toward Wake ForestfLoulsburg fproceed 8.8 miles). Proceed on Capitol Btvd t(3_ Burlington Mills Rd. Go past Burlington Mills Road
make a Ll4um at the first median turn cut. Proceed approx. 800 feet to Teletec Plaza and turn right. The plant is at the end of the road.
4) This NPDES Permit Appf[cation applies to which of the following :
❑ New or Proposed Facility Date operation is to begin
® Existing
5) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 3 2 7 3
6) Provide a brief description of the types of industrial activities and products produced at this facility
(include a site process diagram with this submittal):
The subject facility stores. convevs and wet mixes all of the materials required to produce concrete.
Subsequent to the wet mixing of the concrete, the concrete is loaded onto trucks, and the trucks are sent to
construction sites. Concrete production related activities at the facility include truck drum wash outs, truck
washing, and limited vehicle maintenance
Page 1 of 4
Slam)-229-1017M
l CC EWE �
.D
DEC 2 8 Z604
DENR - LIVATER QUALITY
-V -11
NCG140000 N.O.t.
7) Discharge points i Receiving waters.
How many discharge points (ditches, pipes, channels, etc.) convey stormwaterfrom the property"? _One ---
1^ihat is the name of the booty or bodies of rater (creek, stream. river. lake, ett&) that the facility storm eater
discharges end up In? An unnamed tributary of the Neuse Rivers euse River is apQrox_0.5 miles to the west.)
If the site stor nxate r discharges to a separate storm sewer system, name the operator of the separaEte storm
seLwrsystem (e.g. City of Raleigh municipal storm sefver).
Receiving refer classification (if kna,ti ): WS IV1NSW�Nijuse River)
Note: Discharge of process wastewater to receiving waters classified as WS-II to WS-V or SA must
be approved by the N.C. Dept of Environmental Health. If DER does not approve, coverage
LinderNCG140DDO cannot be granted. No new discharges of process wastewater are permitted
in receiving v�ators classified as WS-I or freshwater ORW
8j Does this facility have any other N P D E S permits?
® No
❑ Yes
If yes, list the pernut numbers for all current NPDES permits for this facility.
9) Does this facility have any Nan -Discharge permits {ex: recycle permits)?
® No
❑ Yes
If yes, list the permit numbers for all current Noml3ischarge permits for this facilly.
10) Does this facility employ any best management practices for stormwater control?
❑ No
® Yes
If yes. please briefly describe: Currently 11 utbect facilitXutilizes a six cell settling pond for suspended
earticle settlement. rior to off site drainage, a reaclin ssys em forprrocess waters and a settlingbasin for
y----_
catching !fines from surface flows off of the Llant lot__-------
11) Does this facility have a Stormwater Pollution Prevention Plan?
® No (NOTE: A Stormwater Pollution Prevention Plan is currently being developed for the subject
❑ Yes facility by Froehling & Robertson, Inc., Raleigh, NC. See Bill Rice at (919) 828-3441.
If yes, when fins it imp lamented? ---------------......._ ---_-------_ --
12) Are vehicle maintenance activities occurring at this facility?
❑ No
® Yes
13) Are discharges occurring from any of the following process wastevrater generating activities?
Vehicle and equipment cleaning ® Yes ❑ No
(Netting of rare material stockpiles ® Yes ❑ No
rAxing drum cleaning ® Yes ❑ No
If yes to any of the above, please describe the type of process used to treat andfor recycle the process
wasterwater. Give design specifics (i.e. design volume, retention time, surface area, etc.). [Use separate
sheet(5)[ (NOTE: See attachment after page 4 of 4 of this application.)
Note: Construction of any wastewater treatment facilities require submission of three (3) sets
of plans and specifications along with this application. Design of treatment facilities
must comply with regtArements 15A NCAC 2H .0138.
Page 2 of 4
Swu-229- 1D17o1
NCG140000 N.O.I.
14) Does the facility use a recycle system?
❑ No
® Yes
If yes, does the system overflow only during ra infa iI events exceieding the 10-yr, 24-hr rainfall if -rent? ❑ Yes ® No
If yes. provide plans, calculations. and supporting documentation.
15) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatmerd, Storage, or Disposal Fad lity?.
M No (NOTE: The facility stores limited vehicle maintenance materials (motor oil, diesel,
❑ Yes lubricants), concrete colorants/additives and cleaning solvents, but these are for site use,
not stored for hazardous materials storage purposes only.
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous caste generatad per mordh) of
hazardous waste?
® No (NOTE: Based on a review of the RCRIS Database on the EPA Website found at
❑ Yes http:/Avww.er)a.00v/recion4/r4data/rcris/rcr nc.txt, date of search 11:00am 12/23/04).
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous wasto generated par month) of
hazardous waste?
® No (NOTE: Based on a review of the RCRIS Database on the EPA Website found at
❑ Yes http:/Avww.epa.gov/region4/r4data/rcristrcr nc.txt, date of search 11:00am 12/23/04).
d) If you answered yes to questions b. arc., please provide the following information:
Type(s) of vmste:--.----.—_.--
JlIQ .ApPli.cable_-----...-----------.—
How is material stored: _-----_
— NQt Ape --------_-------
ti°lhere is material stored:-------
Not Applicable _________ ______
How many disposal shipments peryear._
Not Applicable---- -----------
idame oftransport !disposal vendor._--
—
Not Applicable — — — — — -
- — — — — — — —
Vendor address: — — — — — — — — —
— Not Applicable
16) Certification:
North Carolina General Statute 143-21s.6 b (i) provides that:
Any parson uho imam» gtf maKas ari f False slalarne-Td. representiftoo, or orBncanon in arrj applealtm, record, rEpcK
pier or ofhei docunent 11W or recluted to be niahrahed urrJa Article 21 or re4philons of The En•Aromental
t lanaWw-nl Cam fission Implemenli g Mal ArliCls, or *Mio falsities, tamp►_4s ,.%i1h of krxraingty raMers Inaccurate any
recorkrirg or month" der rc- or mEMcd ieq nM to be qaated or mEM1 trte-c! urrier Article 21 or regUatrns or the
EMbournxd9 f, wngE nerd CammGsbn truplemring Mal Filicie, shal be gupy of a rnMemarior puntshatle by a
arP- not to eaacaM $10A01, or by Imprtymn era not to ems] six rr MIU, or by both. (18 U.S.C. Section 1001 pm -lies
a prnlsbrnerd tv a tine of not more tir3n $40000 or trnprisonnwd mi more Man 5 wa5, or boih. Inr a stnUlar otrense.)
I hereby request coverage under the referenced General Permit. I understand that covorage under this permit
wig constitute the perm it roq uirements for the discharge(s) and is enforceable in the sit me manner as an
indMidual permit -
I certify that I am familiar with the information canto ined in this application and that to the best of my knoMadge
and belief such information is true, complete. and accurate.
Printed blame of Person Signing- _William T. Rice II---�----------
Title: Environmental Planninnc Mana�c e�Ffoehlincg 8� Robersoylnc. LConsultant to Thomas Concrete)
December 23, 2004
( �,�rU�-e o A.pptca)�-------------------- (Dare S,greO
Page 3 of 4
SVWU-223 tat 701
NCG140000 N.O.I.
Notice of Intent must be accompanied by a check or money order for $80.00 made payable to:
NCGENR
1101[liill'19if
This application will be returned as incomplete unless all of the following items have been included:
hock for 580 made payable to NCDEN R
This completed application and all supporting documention
Copy of county map or USGS quad sheet vith location of facilihi clearly marked on map
MaiI the entire package to:
Storm%,ater and General Permits Unit
Division of later Quality
1617 Mail Sep/ice Center
Raleigh. North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of an NPDES permit.
Page 4 of 4
SM-225-101701
Response to 13.) Continued from Page 2 of 4.
If yes to any of the above, please describe the type of process used to treat andfor recycle the process
wastewater. Give design specifics (i.e. design volume, retention time, surface area, etc.).
• Vehicle and Equipment Cleaning. Currently process water flows from vehicle washing are routed into the settling
pond via gravity flow. There is no other form of on -site equipment cleaning that that occurs on a regular basis.
• Wetting of Raw Materials. The only raw material stockpile that requires wetting is the light -weight aggregate
stockpile (shown on the attached figure). Run off from this pile runs onto the lot and into the perimeter curb drainage
channels, ultimately ending into the aforementioned on -site settling basin for catching fines from surface flows off of
the plant lot .
• Mixing Drum Cleaning. Truck mix drums are washed out and purged directly into the first settling pond cell where
their suspended solids settle out as waters slowly travel into the successive pond cells via gravity flow. The mix plant
drum is purged up to twice a day, depending on business volume. Purged material and water from the mix plant is
dropped into a truck and driven to the first settling pond cell.
• Design Volume, Retention Time, Surface Area, Etc. Currently, the subject facility is in the process of being
studied for purposes of developing a Storm Water Pollution Prevention Plan (SP3). At this current time, no data exists
that would sufficiently respond to the questions regarding volume, retention time, and surface area of the existing
stormwater treatment facilities. Performance of the existing and any proposed BMPs will be discussed with the DWQ
and Thomas Concrete during the development of the forthcoming 5P3.
Stormwater Pollution Prevention Plan
Thomas Concrete of the Carolinas
Wake Forest, North Carolina Plant
SITE TOPOGRAPHIC MAP
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Plant Site indicator
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North
Client:
Thomas Concrete of the Carolinas
sewer
FROI=HLING
8 ROBERTSON, INC.
Project:
Wake Forest Concrete Plant
FGEOTECHNICAL+
ENVIRONMENTAL
Location:
2621 Teletec Plaza, Wake Forest, NC
MATERIALS ENGINEERING
'Over one
a LABORATORIES
hundred years of service"
Latitude:
35.92106
Longitude:
78.54745
Iasi
7.5 Quad:
"Wake Forest, NC" Dated 1993
P1•iving Directions from 3800 Barrett Dr, Raleigh, NC to_Burlington Mills Rd & Capital ... Page 1 of 2
�.&A
kP EST _
8 Send To Printer Back To Directions
Start: 3800 Barrett Dr
Raleigh, NC
27609-7222 US
End: Burlington Mills Rd & Capital Blvd
Wake Forest, NC
27587 US
Distance: 11.40 miles
Total Estimated Time: 16 minutes
Directions Distance
.. ................................................................................................................................................................. ............................
1. Start out going WEST on BARRETT DR toward HAWORTH DR. <0.1 miles
.................................................................................................................. ...................................................'--...............................
2. Tum RIGHT onto SIX FORKS RD. 0.3 miles
.. - .. .... ... --............................................................................................................................................1.
N., , 3. Merge onto I-440 E/US-1 N. 2.0 miles
OAT Merge onto CAPITAL BLVD/US-1 N via EXIT 11 toward WAKE
1 4" 8.8 miles
FOREST/LOUISBURG.
.................................................................................................. ...... ..............................................................................................
IM S. End at Burlington Mills Rd & Capital Blvd, Wake Forest, NC 27587 US
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http://www.mapquest.comldirections/main,adp?do=prt&mo—ma&2si=gdt& lgi=d&un=m... 12/22/2004
Light Weight
Aggregate
(wetted every
other week
depending
on need)
c
...........
i
Eioppers
vel ` Aggregate
(wetted only during
periods exceeding
90 degrees,
and depending
on need)
Stone
(wetted on a per ,
job basis during
periods exceeding i
90 degrees
\ [usually only
- twice per year]) ! Ian f 1�
/
/
/
Dry colorants and
concrete additives
.;
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44
NCG140350 January 25, 2005
B. Georgoulias
Thomas Concrete —Wake Forest Plant
rev. 3/22/05
Summary
This facility submitted a Notice of Intent to be covered under General Permit NCG140000
(Ready Mix Concrete). This facility is a concrete ready mix plant. The
stormwater/wastewater discharge drains to an unnamed tributary (UT) to the Neuse
River, a Class WS-IV NSW stream in 'the Neuse River Basin. This facility is located in
Wake County, handled by the Raleigh Regional Office.
Application review
a) The permit application has been signed and sufficiently completed. No;
consultant signed the application. Correction rec'd 2/4/05.
b) The SIC code accurately describes this facility's activities and is covered by this
general permit. Yes. SIC: 3273 (Ready -mix Concrete)
c) Does this facility have other permits? No.
d) Hazardous Waste Activities? No.
e) Stormwater BMPs and Wastewater discharge:
Process wastewater from vehicle and equipment cleaning, and raw stockpile
material wetting is supposedly routed to the multiple -celled settling basin - recycle
pond system (see site schematic). Mixing drum washout water is purged directly
into the first settling pond cell. The application indicated "purge material and
water from the mix plant" is transported via truck to the first settling pond cell.
Per contact (F&R consultant Bill Rice), about twice a day, mix plant material
(roughly 2-3.5 cu. ft. of material in 500 gal. water) is dropped into first settling
basin, which drains to the recycle pond —somewhat similar to mix drum clean -
out water. Whether it can be called mix drum washout or not, it should be
covered under "process wastewater associated with Recycle Systems" in the
NCG14 Permit. Facility attempts to recycle all process wastewater at the site.
An adjacent storm drain also captures runoff from the site and channels water to
a "trough" behind the settling basin cells and recycle pond. Details regarding
volume, retention time, and surface area of stormwater detention facilities and
recycle basin system were not available for the application-, performance. of
current treatment facilities and any proposed modifications will be evaluated
during development of the Storm Water Pollution Prevention Plan. After 2/ 15
site visit with RRO staff (see 2/17 Memo to File), it is apparent that (1) more
steps should be taken to segregate stormwater and process wastewater, and (2)
BMPs in place (structural and non-structural) are not adequate and will need
improvement.
There is evidence of frequent stormwater and wastewater commingling prior to
discharge. For example, the yard is washed down daily, and practices (as well as
lack of berms, etc.) do not prevent some of that water from entering the storm
NCG140350
January 25, 2005
B. Georgoulias
drain. F&R consultants are working with regional office staff' as they develop
plans for several Thomas Concrete facilities, with the objective of meeting
stormwater permit requirements and water quality standards.
Because the Wake Forest Plant is already in operation, issuing this facility a COC
for the NCG14 permit should compel the company to take immediate actions to
comply with permit conditions (and not simply make the site subject to
"operating without a stormwater permit.") The facility would then be obligated
to develop its Stormwater Pollution Prevention Plan (SP3) within one year (but
encouraged to finish it sooner).
DWQ has decided to address this and similar sites already in operation as
follows:
(1) Issue the COC under NCG14. This will prompt SP3 development and
urgency for modifying and/or designing new BMPs/WW treatment facilities
to meet requirements of NCG14.
(2) DWQ Regional Office staff' will then follow-up with a letter to the company
requesting that it submit plans and specifications for new/modified
stormwater BMPs, wastewater treatment facilities, etc. to both the central and
regional offices, within a specified time -frame.
(3) DWQ central office staff will work with the regions to conduct a technical
review of the design basis, etc. DWQ (either the central or regional office)
will issue an Authorization to Construct (AtC) upon plan approval.
f) Regional Office input requested: 1/25/2005, 2/,14 (DWQ), 3/22 (DEH)
RO (DWQ) Approval received: 3/22/2005 (via phone call from M. Nisely)
Phone/Meeting Logs:
1/25/05: Spoke to Myrl Nisely at the Raleigh Regional Office re: issue of purge material
and water from the mix plant going into the pond.
1/25: Spoke with Bill Rice (Froehling & Robertson, 919-828-3441, ext. 334) re: NOI
signature and process wastewater question. Sent additional information request.
2/14: Bill Rice phoned with clarification re: mix plant purge material/water (see review
above, 2/14 e-mail).
2/15: Site visit with M. Nisely (see 2/17/05 Memo to File).
2/18: Meeting at RRO with F&R consultants, Myrl Nisely, and Ken Schuster regarding
DWQ expectations/goals for ready -mix facilities, and issues observed at specific Thomas
Concrete sites.
3/22: Verified that once COC issued, RRO will send letter instructing Thomas Concrete to
submit plans/specs for planned S/W BMP and WW treatment modifications.
Thomas Concrete's Wake Forest Plant
Subject: Thomas Concrete's Wake Forest Plant
From: "William Rice" <WRice@FandR.com>
Date: Mon, 14 Feb 2005 16:56:20 -0500
To:<Bethany.georgoulias@ncmai1.net>
Hi Bethany,
In response to your question regarding plant mix drum purged materials at the Thomas Concrete Wake Forest
plant, I write the following:
According to Mr. Brian Westfall, Plant Manager for Thomas Concrete's Wake Forest plant, the plant mix drum is
purged up to twice a day during busy periods, dispensing an average of 3.5 cubic feet of concrete solids into truck
mix drums that are driven over and disposed of in the first cell of the plant's recycling/settling pond. The fines and
suspended solids are then subsequently settled out with each successive settling pond cell, and the water is
recycled into batch mixes.
Have a good night,
Bill Rice
Environmental Planning Manager
Froehling & Robertson, Inc.
310 Hubert Street
Raleigh, NC 27603
(919) 828-3441
Ext. 334
I of 1 2/14/2005 5:16 PM
February 17, 2005
Memo
To: File
From: Myrl Nisely and Bethany Georgoulius
Subject: 2/15/2005 Recon of Thomas Concrete Wake Forest Plant for Stormwater Status
Wake Forest, NC
NQI Application Staff Report
Wake County
This plant uses the wet batch method of preparing concrete, mixing the components in an
overhead drum and then dropping the prepared batch into a delivery drum truck. Their
NQI application for NCG14 spoke of "mixing drum purge water", a description new to
us, so we made a visit to better understand what that was.
The mixing drum prepares the client's batches, anywhere from 1 to.-I.0 cubic yards, one at
a time. In hot weather this drum must be washed out about 2x/day..: This •involves 500
gallons of water each time. After stirring, the diluted concrete is usually dropped to a
truck, then is taken across the yard and dumped into a washout pit. The mixing drum
washes are sometimes dropped to the ground. Each truck is also washed out at least once
per day, and sometimes more often. Solids are transported to any of three waste stations,
while the water makes its way through the recycle cells. This facility uses about 100
gallons for its truck drums, instead of the typical 40 to 50 gallons other companies use.
All in all, this site uses more water and discards a much larger volumc`of waste aggregate
than any other facility visited in this regional area.
A series of 4 cells are meant to clarify the dumped water, which then goes into a larger 5`h
cell. From there water is pumped into new batches if quality concerns will allow. A high
fraction of the site slopes to this recycle unit. However, there is some "stormwater" that
goes elsewhere, as described below. The recycle water balance was reported to be in
equilibrium until rain adds to the volume in the recycle system. After a rain, the added
volume is slowly worked down by more closely scrutinizing which customers can use
recycle water. It is also used to hose the impervious yard, returning to recycle again.
This provides some evaporative loss. }
Truck drivers fill their tanks with fresh water, used for washing chutes and the outside of
the trucks.
The sand and gravel dropped into the first cell is scooped up and put into any of three
holding cells. Drainings return to the recycle system. The solids are later trucked away
by an outside processor for reuse.
A portion of the driveway stormwater water makes its way to a storm drain leading into a
final trough running the full length of and behind the recycle stru&tife. The`grate -at the
storm drain was visually loaded with gray paste. A hay bale blockage had been placed
upstream of the storm drain, forcing the water overland. That water ended up outside the
long trough, joining water released from the trough through small opening(s). Released
water is meant to- percolate through a rock structure and/or run overland down a steep. -
bank and eventually to a small creek. There was evidence of concrete materials running
several feet into vegetation ahead of the creek. Attenuation of pH and TSS is needed for
these releases.
Consultants for Thomas, F&R, will meet with the State on 2/18/05 to review plans for, all
Thomas sites. None has a permit at this time, so have no SP3 and no analytical
information on discharges from the site.
Ready Mix Letter,, Thomas Concrete
Subject: Ready Mix Letter & Thomas Concrete
From: Bethany Georgoulias<bethany.georgoulias@ncmail.net>
Date: Tue, 19 Apr 2005 16:06:1 5 -0400
To: Myrl Nisely <myrl.nisely@ncmail.net>
CC: Bradley Bennett <Bradley.Bennett@ncmai1.net>, Ken Pickle <ken.pickle@ncmail. net>, Aisha Lau
<aisha.lau@ncmail.net>, Jonathan Diggs <jonathan.diggs@ncmail.net>, Ken Schuster
<Ken. Schuster@ncmai l.net>
Hi Myrl,
FYI -After incorporating some comments from Ken Pickle on my letter, this is the
revised version I sent out to McLeod Construction today. It might be helpful to you
on future projects in your region. We're also looking into the list of requirements
Non -Discharge (now Aquifer Protection) includes on their Recycle System application as
a starting point for what to ask for in our NCG14 application process as our approach
evolves.
Also, I received DEH's signoff on the Thomas Concrete - Wake Forest Plant this week
and plan to issue the COC by week's end (NCG140350). That means the next step will be
a follow-up letter from you all re: plans & specs for their BMP design improvements
(i.e., the AtC part). Let me know if you want to talk more about that once it's been
issued.
cheers,
BG
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
Myrl Nisely wrote:
Bethany, your set of design questions make a terrific base for future
interrogations of consultants and facility managers. If we can persuade the
industry to design around those issues, they will move toward the compliance we are
expecting. Thanks!
Myrl
MacLeod addinfo ltr.doc Content -Type: applic ation/m sword
Content -Encoding: base64
i of 1 5/23/2005 2:37 PM
NCG140350
January 25, 2005
B. Georgoulias
Thomas Concrete —Wake Forest Plant
rev. 6/8/05
Summary
This facility submitted a Notice of Intent to be covered under General Permit NCG140000
(Ready Mix Concrete). This facility is a concrete ready mix plant. The
stormwater/wastewater discharge drains to an unnamed tributary (UT) to the Neuse
River, a Class WS-IV NSW stream in the Neuse River Basin. This facility is located in
Wake County, handled by the Raleigh Regional Office.
Application review
a) The permit application has been signed and sufficiently completed. No;
consultant signed the application. Correction rec'd 2/4/05.
b) The SIC code accurately describes this facility's activities and is covered by this
general permit. Yes. SIC: 3273 (Ready -mix Concrete)
c) Does this facility have other permits? No.
d) Hazardous Waste Activities? No.
e) Stormwater BMPs and Wastewater discharge:
Process wastewater from vehicle and equipment cleaning, and raw stockpile
material wetting is supposedly routed to the multiple -celled settling basin - recycle
pond system (see site schematic). Mixing drum washout water is purged directly
into the first settling pond cell. The application indicated "purge material and
water from the mix plant" is transported via truck to the first settling pond cell.
Per contact (F&R consultant Bill Rice), about twice a day, mix plant material
(roughly 2-3.5 cu. ft. of material in 500 gal. water) is dropped into first settling
basin, which drains to the recycle pond —somewhat similar to mix drum clean -
out water. Whether it can be called mix drum washout or not, it should be
covered under "process wastewater associated with Recycle Systems" in the
NCG14 Permit. Facility attempts to recycle all process wastewater at the site.
An adjacent storm drain also captures runoff" from the site and channels water to
a "trough" behind the settling basin cells and recycle pond. Details regarding
volume, retention time, and surface area of stormwater detention facilities and
recycle basin system were not available for the application; performance of
current treatment facilities and any proposed modifications will be evaluated
during development of the Storm Water Pollution Prevention Plan. After 2/15
site visit with RRO staff (see 2/17 Memo to File), it is apparent that (1) more
steps should be taken to segregate stormwater and process wastewater, and (2)
BMPs in place (structural and non-structural) are not adequate and will need
improvement.
There is evidence of frequent stormwater and wastewater commingling prior to
discharge. For example, the yard is washed down daily, and practices (as well as
lack of berms, etc.) do not prevent some of that water from entering the storm
l
NCG140350
January 25, 2005
B. Georgoulias
drain. F&R consultants are working with regional office staff as they develop
plans for several Thomas Concrete facilities, with the objective of meeting
stormwater permit requirements and water quality standards.
Because the Wake Forest Plant is already in operation, issuing this facility a COC
for the NCG14 permit should compel the company to take immediate actions to
comply with permit conditions (and not simply make the site subject to
"operating without a stormwater permit.") The facility would then be obligated
to develop its Stormwater Pollution Prevention Plan (SP3) within one year (but
strongly encouraged to finish it sooner).
DWQ has decided to address this and similar sites already in operation as
follows:
(1) Issue the COC under NCG14. This will prompt SP3 development and
urgency for modifying and/or designing new BMPs/WW treatment facilities
to meet requirements ofNCG14.
(2) DWQ Regional Office staff will then follow-up with a letter to the company
requesting (1) the status of SPPP and BMP plans, and (2) in what time frame
the Permittee will submit plans and specifications for new/modified
stormwater BMPs, wastewater treatment facilities, etc. to DWQ.
(3) DWQ central office staff will work with the regions to conduct a technical
review of the design basis, etc. DWQ (either the central or regional office)
may also issue an Authorization to Construct (AtC) upon plan approval (but
need to work out a process for this).
f) Regional Office input requested: 1/25/2005, 2/14 (DWQ), 3/22 (DEH)
RO (DWQ) approval: 3/22/2005 (via phone call from M. NiseIy)
RO (DEH) Public Water Supply approval: 4/ 18/2005 (Memo)
Phone/Meeting Logs:
1/25/05: Spoke to Myrl Nisely at the Raleigh Regional Office re: issue of purge material
and water from the mix plant going into the pond.
1/25: Spoke with Bill Rice (Froehling & Robertson, 919-828-3441, ext. 334) re: NOI
signature and process wastewater question. Sent additional information request.
2/14: Bill Rice phoned with clarification re: mix plant purge material/water (see review
above; 2/14 e-mail).
2/ 15: Site visit with M. Nisely (see 2/ 17/05 Memo to File).
2/18: Meeting at RRO with F&R consultants, Myrl Nisely, and Ken Schuster regarding
DWQ expectations/goals for ready -mix facilities, and issues observed at specific Thomas
Concrete sites.
r
NCG140350 January 25, 2005
S. Georgoulias
3/22: Verified that once COC issued, RRO will send letter instructing Thomas Concrete to
submit plans/specs for planned S/W BMP and WW treatment modifications.
6/8: Meeting with K. Schuster and M. NiseIy at RRO to sort out follow-up procedure.
RRO will send a letter to Thomas asking for the status of the SPPP and BMP/treatment
facility modification plans, and ask the company to commit to a time -line for submitting
plans and calcs demonstrating ability of design to achieve compliance. Discussed how 12-
month compliance window for preparing SP3 in the general permit does not necessarily
grant a 12-month "grace period" for meeting wastewater discharge limits, which are effective
on the first day of the COC (even though the SP3 under development must consider the
interaction of stormwater and wastewater at the site) —underscores the need for the
company to show progress a lot sooner. RRO will copy us on the letter.
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February 17, 2005
Memo
To: File
From: Myrl Nisely and Bethany Georgoulius
Subject: 2/15/2005 Recon of Thomas Concrete Wake Forest Plant for Stormwater Status
Wake Forest, NC
NOI Application Staff Report
Wake County
This plant uses the wet batch method of preparing concrete, mixing the components in an
overhead drum and then dropping the prepared batch into a delivery drum truck. Their
NOI application for NCG14 spoke of "mixing drum purge water", a description new to
us, so we made a visit to better understand what that was.
The mixing drum prepares the client's batches, anywhere from 1 to 10 cubic yards, one at
a time. In hot weather this drum must be washed out about 2x/day. This involves 500
gallons of water each time. After stirring, the diluted concrete is usually dropped to a
truck, then is taken across the yard and dumped into a washout pit. The mixing drum
washes are sometimes dropped to the ground. Each truck is also washed out at least once
per day, and sometimes more often. Solids are transported to any of three waste stations,
while the water makes its way through the recycle cells. This facility uses about 100
gallons for its truck drums, instead of the typical 40 to 50 gallons other companies use.
All in all, this site uses more water and discards a much larger volume of waste aggregate
than any other facility visited in this regional area.
A series of 4 cells are meant to clarify the dumped water, which then goes into a larger 5`h
cell. From there water is pumped into new batches if quality concerns will allow. A high
fraction of the site slopes to this recycle unit. However, there is some "stormwater" that
goes elsewhere, as described below. The recycle water balance was reported to be in
equilibrium until rain adds to the volume in the recycle system. Auer a rain, the added
volume is slowly worked down by more closely scrutinizing which customers can use
recycle water. It is also used to hose the impervious yard, returning to recycle again.
This provides some evaporative loss.
Truck drivers fill their tanks with fresh water, used for washing chutes and the outside of
the trucks.
The sand and gravel dropped into the first cell is scooped up and put into any of three
holding cells. Drainings return to the recycle system. The solids are later trucked away
by an outside processor for reuse.
A portion of the driveway stormwater water makes its way to a storm drain leading into a
final trough running the full length of and behind the recycle structure. The grate at the
storm drain was visually loaded with gray paste. A hay bale blockage had been placed
upstream of the storm drain, forcing the water overland. That water ended up outside the
long trough, joining water released from the trough through small opening(s). Released
water is meant to percolate through a rock structure and/or run overland down a steep
bank and eventually to a small creek. There was evidence of concrete materials running
several feet into vegetation ahead of the creek. Attenuation of pH and TSS is needed for
these releases.
Consultants for Thomas, F&R, will meet with the State on 2/18/05 to review plans for all
Thomas sites. None has a permit at this time, so have no SP3 and no analytical
information on discharges from the site.
Re: Thomas Concrete's Wake Forest Plant
Subject: Re: Thomas Concrete's Wake Forest Plant
From: Bethany Georgoulias <bethany.georgoulias@ncmail.net>
Date: Wed, 16 Feb 2005 17:30:05 -0500
To: William Rice <WRice@FandR.com>
CC: myrl nisely <myrl.nisely@ncmail.net>
Thanks for supplying this information, Bill.
I was actually out at the Wake Forest Plant site yesterday with Myrl Nisely, who'll
be doing the regional office review of this site's stormwater permit application. He
mentioned that F&R would be at his offices on Friday morning for a meeting and has
invited me to sit in, so we can talk a little more about this site in particular
then.
I don't think I need anything else from you before them. Myrl and I do have a few
concerns with this site, in particular the segregation of storm water drainage from
things like yard washdown (which isn't a process wastewater specified in the general
permit as being allowed into stormwater conveyances). There were also some other
issues, such as evidence of concrete -contaminated drainage that is simply bypassing
the settling basin system and stormwater drain; however, I understand that may (and
should) be something F&R would address in developing a stormwater pollution
prevention plan and any BMP designs to meet the requirements of the stormwater
permit. These issues may not preclude this plant from qualifying for the general
permit coverage; however, it will be worthwhile to talk about how to address these
challenges for this and similar sites. In addition, I know it will be important to
Myrl to feel comfortable with the plans to resolve these concerns before approving
the NOI.
I look forward to seeing you Friday.
Thanks,
Bethany Georgoulias
Environmental Engineer
NC DENR DW4
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
William Rice wrote:
Hi Bethany,
In response to your question regarding plant mix drum purged materials at the
Thomas Concrete Wake Forest plant, I write the following:
According to Mr. Brian Westfall, Plant Manager for Thomas Concrete's Wake Forest
plant, the plant mix drum is purged up to twice a day during busy periods,
dispensing an average of 3.5 cubic feet of concrete solids into truck mix drums
that are driven over and disposed of in the first cell of the plant's
recycling/settling pond. The fines and suspended solids are then subsequently
settled out with each successive settling pond cell, and the water is recycled
into batch mixes.
Have a good night,
Bill Rice
Environmental Planning Manager
Froehling & Robertson, Inc.
1 of 2 2/ 16/2005 5:31 PM
Re: Thomas Concretes Wake Forest Plant
310 Hubert Street
Raleigh, NC 27603
(919) 828-3441
Ext. 334
of 2 2/16/2005 5:31 PM
Thomas Concrete -Wake Forest Plant
Subject: Thomas Concrete -Wake Forest Plant
From: Bethany Georgoulias <bethany.georgoulias@ncmail.net>
Date: Mon, 14 Feb 2005 17:22:45 -0500
To: myrl nisely <myrl.nisely@ncmail.net>
Myrl,
I talked with Bill Rice today re: Thomas Concrete Wake Forest Plant. After talking
with the site contact, he clarified what the "mix plant purge material" was that is
dropped into trucks and driven to the settling pond basin (see Bill's e-mail below).
Even though it is very similar to, but not technically the same as mix drum washout
water, I think it should still be covered under 'process wastewater associated with
Recycle Systems' in NCG14.
Anyway, I wanted to go ahead and request the RRO's input on issuing this facility a
COC for coverage under NCG140000. Since I'll see you tomorrow, I'll bring a copy of
the NOI and my review summary then, and we can talk a little more about it. Here are
the facility details:
Thomas Concrete - Wake Forest Plant
COC # NCG140350
2621 Teletec Plaza
Wake Forest, Wake County
Contact: Brian Westfall, tel. 919-562-1909
Site discharges to a UT to the Neuse River, classified as WS-IV NSW in the Neuse
Basin. DEH's input will be requested as well, since this permit involves wastewater
discharge.
Does the RRO have any issues or concerns with issuing this site coverage under
Stormwater General Permit NCG140000?
Thanks, BG
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
-------- Original Message ----------
Subject: Thomas Concrete's Wake Forest Plant
Date: Mon, 14 Feb 2005 16:56:20 -0500
From: William Rice <WRice@FandR.com>
To:<Bethany.georgoulias@ncmail.net>
Hi Bethany,
In response to your question regarding plant mix drum purged materials at the Thomas
Concrete Wake Forest plant, I write the following:
According to Mr. Brian Westfall, Plant Manager for Thomas Concrete's Wake Forest
plant, the plant mix drum is purged up to twice a day during busy periods, dispensing
an average of 3.5 cubic feet of concrete solids into truck mix drums that are driven
over and disposed of in the first cell of the plant's recycling/settling pond. The
fines and suspended solids are then subsequently settled out with each successive
settling pond cell, and the water is recycled into batch mixes.
Have a good night,
I of 2 2/ 14/2005 5:23 PM
Thomas Concrete --Wake Forest Plant
Bill Rice
Environmental Planning Manager
Froehling & Robertson, Inc.
310 Hubert Street
Raleigh, NC 27603
(919) 828-3441
Ext. 334
2 of 2 2/14/2005 5:23 PM
Thomas Concrete General Stormwater Permit Application
r
Subject: Thomas Concrete General Stormwater Permit Application
From: Bethany Georgoulias<bethany.georgoulias@ncmaii.net> C
SA.
Date: Tue, 25 Jan 2005 L 3:25:58 -0500
To: wrice@fandr.com Lr�,
CC: myrl niseiy cmyrl.nisely@ncmail.net>, Joe Albiston <Joe.Albiston@ncmail.net> 1�
Re: Application for Stormwater General Permit NCG140000, COC# NCG140350
Thomas Concrete - Wake Forest Plant (2621 Teletec Plaza)
(1) NOI Signature needed from Company Official
(2) Process wastewater clarification
Good Afternoon Mr. Rice,
I've just begun reviewing the NOI application for Thomas Concrete's Wake Forest Plant
for coverage under the stormwater general permit NCG140000 (Ready -mix concrete), and
I've encountered two issues that need attention:
1) I noticed that you signed the application. The application must be signed by an
appropriate company official (such as a principal executive officer of Thomas
Concrete, or his/her duly authorized representative responsible for operation of the
facility), and not the consultant. (That permit application signatory requirement is
outlined in our NC Rules, T15A NCAC 02H .106). Rather than return the application at
this point, if you can provide a hard copy with the appropriate signature as soon as
possible, I will hold on to the NOI and proceed with review. if you wish to fax me a
copy sooner, our fax number is (919) 733-9612.
2) The application response to question 13. indicates "Purged material and water from
the mix plant is dropped into a truck and driven to the first settling pond cell."
Could you please clarify what type of process wastewater that is and what kind of
volumes we're talking about? In addition to stormwater discharge, the NCG14 general
permit includes (1) vehicle and equipment cleaning, (2) recycle system overflow, (3)
raw material stockpile wetting, and (4) mixing drum cleaning, but I'm uncertain about
whether what you've referred to as 'mix plant purge material and water' is covered.
Regarding the second item, I just spoke with Myrl Nisely at the Raleigh Region, and
he let me know F&R will be at their offices this Friday. Since I asked him about
this issue at ready -mix plants, Myrl is planning to inquire about the Wake Forest
site, so hopefully you will have a chance to discuss it further with regional staff
if needed. Please feel free to e-mail me or call me (919-733-5083, ext. 529) if you
have any questions. Unfortunately I won't be available to visit the regional office
on Friday, but I will touch base with Myrl after the meeting.
Thank you,
Bethany Georgoulias �}
Environmental Engineer j'i
NC DENR DWQ v 1 f
Stormwater Permitting Unit
(919) 733-5083, ext. 529
bethany.georgoulias@ncmail.net
1 of 1 1/25/2005 1:26 PM