NCG140328_COMPLETE FILE - HISTORICAL_20061219

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE,
r] HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑
YYYYM M DD

\W A7F
W�p1
Tony L. Sample
Carolina Sunrock, LLC
P.O. Box 25
Butner, NC 27509
Dear Mr. Sample:
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
December 19, 2006
SUBJECT: Acknowledgment of Receipt of
Case No. PC-2006-0008
Permit No. NCG140328
Wake County
r,FNR RP�EIGH R�`yr!
This letter is to acknowledge receipt of check # 086996 from Carolina Sunrock, LLC in the amount of
$7,796.89 received on November 28, 2006. The balance of the penalty is. $0.00.
This payment satisfies in full the.civil assessment in the amount of $7,796.89 levied against Carolina
Sunrock, LLC and this enforcement case has been closed.
Payment of this penalty in no way precludes further action by this Division for continuing or
future violations. You are encouraged to contact Ron Boone with the DWQ Raleigh Regional
Office at [phone] if you need assistance in achieving compliance at the site.
If you have any questions please call Shelton Sullivan at [phone] ext. 544.
Sincerely,
Shelton Sullivan
NPS Assistance & Compliance Oversight Unit
cc: Charles Wakild, P.E. — DWQ Raleigh Regional Office Supervisor
Ron Boone — DWQ Raleigh Regional Office Staff
NPS Assistance & Compliance Oversight Unit — File Copy
DWQ Central Files
0.
XhCarolina
turally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.newaterquality ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% RecycledA O% Post Consumer Paper

I
CAROLINA SUNROCK LLC
Tony Sample, CPESC
Compliance Manager
200 Horizon Drive, Suite 100
Raleigh, NC 27615
March 12, 2012 1
L
Raleigh ReionalOffice I(jII _ i012 il�J'
NCDENR, DWQ
3800 Barrett Drive---,-:--�
Raleigh, NC 27609
Certified Mail: 70051160 0003 1720 1772
Return Receipt Requested P1 r
\' I� l
9 ar'' ✓n
k w� Ifrzcil11�ezi
Re: Permit Nos. NCG140251, NCG140328, NCG160161, NCO20438, NCG0200072, and NCG020438
RDU Facility, N� Plant, MDC Plant, Kittrell Quarry, Butner Quarry and Woosdsdale Quarry
Carolina Sunrock LLC
Wake County, Durham County, Granville County, Vance County and Person County
Dear Sir/Madam:
Please find attached the above referenced Discharge Monitoring for our Facilities.
An asterisk (*) indicates storm event does not meet the definition of a sample able Storm.
Please contact us if you need further information or if this does not meet your requirements.
Sincerely,
Carolina Sunrock, LLC
Tony L. Sample, C.P.E.S.C.
Compliance Manager
[e-mail]
Phone: 919,747,6336
Fax: 919.747,6305
wwva.thesunrockgroup.cem

w
CAROLINA SUNROCK LLC
March 12, 2012
Central Files
NCDENR,DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Certified Mail: 70051160 00031720 1789
Return Receipt Requested
Re: Permit Nos. NCG140251,.NGG1.40328; NCG160161
RDU Facility, NR Plant, and MDC Plant, Carolina Sunrock LLC
Wake County, Durham County
Dear Sir/Madam:
Please find attached the above referenced Discharge Monitoring for our Facilities.
Please contact us if you need further information or if this does not meet your requirements.
Sincerely,
Carolina Sunrock, LLC
ony L. ample, C.P.E.S.C.
Compliance Manager
Tony Sample, CPESC
Compliance Manager
200 Horizon Drive, Suite 100
Raleigh, NC 27615
tsample@thesu nroc kg roup.com
Phone. [phone]
Fax 919.747,6305
www. t hesu n rockg roup.com

STORNIWATER DISCHARGE MONITORING REPORT (DNIR)
11 Please Mail Original and One Copy to flailing Address Below
GENERAL PERMIT NO. NCG01410000
Part A: Facility lofarmation
p
Samples Collected in Calender Year:
2011 (all samples shall be reported within 30 days following monitoring period)
Certificate of Case rage No.
NCG140328
County of Facility
Wake
Facility Name
NR Plant
Name of Ltdo razors
Pace Anahaical
Facillity Contact
TONY SAMPLE
Lab Certification N
9282381001
Facility Contact Phone No.
[phone]
Does this facility perform \'chicle Maintenance
Activities using more that 55 gallons of new motor oil per month?
f es _ _ No
(if, es, complete Pan B)
Part A: SP,.ftc MonlonmR Reaw ememn
Part B: Vehicle Maintenance Monitarine Requirements
'-Outfall_"
.No.-..�
t 4 '
;Recemng Sveatm
.... ;Name t_
_Date --
-00050:
,00530
_:.r,-
•as<. ;,.. :.=x. d..
"Sam01e
Collected
•. -
_ ..
Total
S Flow
._Total
Suspended
Sodds
=i.* .
_
:'n. j
-, '¢_.
:motddtvr..
MG, -
'_m 7..
.":.: �__
.�>_ ,•• .a.,^
001
Nlnbto Smith Coc
10/12/11
7 7
Part D: Srorm Event Characteristics
Date 10.!12/2011
Total Event Precipitation (inches) 1.03
Event Duration (hours) 5
Part F.: Certification
s:
Oirtfallr
�No -..Name..:_.-...
I aN':w
tt Receiving Stream
--C1.Date r
-30050
t.00556.:
i _00530. 'M
.' 00400
tit ample
Collected
c.-:.
Total
_.. Flown:
Od auJ i
Greaser;
L ^sTotal' s .f
Suspended '> 1
'.,rt-='. Soilds3
'; T
TpH 1
-
New Motor
iOii,Usage,
-
...r.a
imo7ddivc
• • MG'--.+
. m -•S
-.._ -
t+ __gym Is ,' -
..<-.unities
__
.-Ilmomh7
001
JN trib to Smith Creek
Date
Total Event Precipitation (inches)
Event Duration (hours)
lift, separate storm event is sampled)
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false i rmation,
including the possibility of fines and imprisonment for knowing violation."
3/6/12
(SignaNr mitee (Date)
Part D: Mailing Addrevs
Attn: Central Files, NC DENR, Disision of Water Qualit), 1617 Mail Service Center, Raleigh, N.C. 27699-1617
L
4
L!�h 201Z II IJ
roc o�,+R

,\
\ w
1A:JII1C10
To: Alan Klimek
CC: Priscilla Benson
From: Chuck Wakild— DWQ Raleigh Regional Office Supervisor
Date: 9/14/2006
Re: Case No. PC-2006-0008 Remission request for Carolina Sunrock, LLC — Wake Forest,
Wake County, NC
Case Background and Assessment
• December 22, 2005 — RRO conducted a site visit and observed observed various violations of the
conditions of the General Stormwater NPDES Permit NCG140000.
• July 27, 2006 — Carolina Sunrock, LLC was assessed $7,796.89 total: $500 for failure to have an
adequate site plan, $500 for failure to develop an adequate stormwater management plan, $500
for failure to keep an adequate Spill Prevention and Response Plan, S500 for failure to maintain
an adequate housekeeping program, $500 for failure to develop and adequate employee training
program, $500 for failure to keep a list of personnel responsible for the Stormwater Pollution
Prevention Plan (SPPP), $500 for failure to update the SPPPP, $500 for failure to document
facility inspections, $500 for failure to monitor for pH, $500 for failure to monitor for total
suspended solids, $500 for failure to monitor for settleable solids, $1000 for failure to perform
semi-annual qualitative monitoring, and $1,000 for failure to control the pH level of wastewaters
discharged from the site to with the required range, plus investigative costs.
• August 2, 2006 — Green card indicated delivery of the assessment document to Carolina Sunrock,
LLC.
Remission Request (Brief Summary)
• August 24, 2006 — Remission request signed.
• August 26, 2006 — Received remission request.
Mr. Tony Sample responded on behalf of Carolina Sunrock, LLC. Mr. Sample states that the
company worked promptly to abate the violations. He states the violations resulted from the first
site visit ever to the facility and that they he feels that the fine is too high for the potential harm to
the environment and that DWQ is more interested in citing operators than helping to prevent
pollution in the State. Mr. Sample states that Carolina Sunrock, LLC was aware of the high pH
problem related to their runoff and that they have been working to correct the potential problem
since 2004. An Authorization to Construct for a recycling weir was received on August 3, 2206
after 1963 days in review by DWQ, He states that while their SPPP plan was disorganized and
complete, at least they had a plan are were attempting to comply with their Stormwater Permit.
He states that construction of the weir is going to cost the company $65,000.00 and feels there is
no added value to the environment for the fine. A copy of the SWPP and a page showing
signatures and dates as to when the Spill Prevention, Control, and Countermeasure (SPCC) Plan
was reviewed was submitted with the package.
Remission Recommendation from RO and CO
• RRO recommends no remission of the civil penalty assessment. The violator has not proven I.)
That they have abated continuing environmental damage and 2.) That payment of the penalty willp.,
prevent pavment of remaining necessary remedial actions. NprthCarofina
Ilvatura//y
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.encstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

• Central Office recommends

DWQ CIVIL PENALTY ASSESSMENT REMISSION FACTORS
CONSIDERATION
Case Number: PC-2006-0008 Region: Raleigh County: Wake
Assessed Entity: Carolina Sunrock, LLC
O (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
Notes:
(X) (b) Whether the violator promptly abated continuing environmental damage resulting
from the violation;
Notes: It is unknown to what extent the violator has abated continuing environmental damage
because no inspections have been conducted at the facility since the 12/05 inspection. It is
believed that the violator has responded favorably to the violations and has acted quickly since
receiving the NOV. However, as with all environmental programs, these actions should have been
more preventative in nature rather than reactive. The violations observed during the 12/05
inspection never would have occurred had the violator implemented and effective stormwater
pollution prevention plan (SP3). However, no SP3 was on site during the 12/05 CEI and
conditions at the site at the time of the inspection reflected that. To our knowledge the structural
BMPs planned by the violator to prevent these types of violations in the future are not yet
installed. Although DWQ required a considerable amount of time to review and approve the AtC,
which the violator brings to light in their response to the enforcement, the AtC and the associated
controls should have been planned, designed, submitted to and approved by DWQ prior to the
start of activities requiring the BMPs in order to remain compliant. It is therefore assumed, unless
the violator has undertaken other interim measures, which DWQ is unaware of, that the
environmental damage witnessed during the 12/05 inspection, is still ongoing to some extent.
O (c) Whether the violation was inadvertent or a result of an accident;
Notes:
O (d) Whether the violator had been assessed civil penalties for any previous violations;
Notes:
(X) (e) Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Notes: The violator has provided absolutely no data that supports their claim that payment of the
penalty would hinder payment of the remaining necessary remedial actions. We therefore cannot
provide a fair assessment of this remission factor.
Decision (Check one)
Request Denied Full Remission Partial remission Amount remitted
Date
Alan W. Klimek, P.E.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 30, 2006
Tony L. Sample
Carolina Sunrock, LLC
PO Box 25
Butner, NC 27509
RE: Request for Remission of Civil Penalty
Carolina Sunrock, LLC
North Raleigh Distribution Center (COC NCG 140328)
Case No. PC-2006-0008
Wake County
Dear Mr. Sample:
Alan W. Klimck, P.E. Director
Division of Water Quality
The Division of Water Quality has received your request for remission of civil penalty
dated August 24, 2006, with accompanying support information. Your request will be
presented to the Director of the Division of Water Quality and you will be notified of the
results.
Should you have any questions, please feel free to call Chuck Wakild with the DWQ
Raleigh Regional Office at [phone] or Priscilla Benson at [phone] ext. 360.
Sincerely,
Karen Higgins
NPS Assistance and Compliance Oversight Unit
cc: Chuck Wakild — DWQ Raleigh Regional Office Supervisor
Ron Boone — DWQ Raleigh Regional Office
NPS Assistance and Compliance Oversight Unit — File Copy
DWQ Central Files
CIA)
tCarolin
411;7//y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Servicc
Internet: www.ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/AKrmatue Action Employer— 50% Recycled/10% Post Consumer Paper

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC-2006-0008 County: Wake
Assessed Party: Carolina Sunrock, LLC
Permit No. (if applicable): NCG140000 Amount Assessed: $7,796.89
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully pplied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
i/ (b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
_ (c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):
SEP — ly 2

STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
CAROLINA SUNROCK, LLC ) STIPULATION OF FACTS .
CASE NO. PC-2006-0008
Having been assessed civil penalties totaling $ 7,796.89 for violation(s) as
set forth in the assessment document of the Director of the Division of Water Quality dated,
July 27, 2006 the undersigned, desiring to seek remission of the civil penalties, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate
that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within
thirty (30) days of receipt of the civil penalty assessment. No new evidence in support of a
remission request will be allowed after thirty (30) days from.the receipt of the civil penalty
assessment.
This the Z day of 20 aG .
6 Z
,i0,6'oc z f
daA,11 , X/C / - 5_�7
TELEPHONE
915' , 7f" y,s oZ.

CAROLINA SUNROCK LLC
August 24, 2006
Ms Karen Higgins
NC Division of Water Quality
NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Assessment of Civil Penalties dated July 31, 2006
Carolina Sunrock LLC
North Raleigh Distribution Center
Case No. PC-2006-0008
Dear Ms Higgins,
Tony L. Sample, CPESC
Compliance Manager
PO Box 25 Butner, NC 27509
Carolina Sunrock LLC would respectfully request remission of the above referenced Assessment. We feel that the
violations were promptly abated and the potential for environmental damage was minimized and was never as high
as the civil penalty amount would suggest. Furthermore, the Notice of Violation on page 5 of 6, specifically pared
the concerns down to three primary issues for assessing the penalty, and the actual assessment had expanded
those three items into 13, half of the amount of the penalty was for paperwork violations and did not involve
potential environmental damage. The site visit that initiated this action was the first time this site had been
inspected, and the perception we have resulting from this inspection, the NOV and the Assessment, is that the
Division of Water Quality is more concerned in Citing Operators than helping prevent the pollution of our State
waters. We are committed to protecting the environment and doing what we can to prevent pollution, and we are
willing to work with the Department to do a better job, but lets all work together.
Carolina Sunrock was aware that something needed to be done to address the runoff at this site and we had been
working to address this potential problem for some time prior to the December 2005 inspection. I have attached a
Chronological History of our activities for this site to assist in convincing you of our positive actions toward
maintaining compliance within our Company. We have been in the planning/permitting stage of operation since
2004 to correct deficiencies that we saw needed addressing at this site. An Authorization to Construct for our
recycling weir was finally received on August 3, 2006 after 193 days of review by the Department. We further admit
that we had a disorganized, incomplete Pollution Prevention Plan, but we did have a plan, we were making an effort
to comply with our Stormwater Permit.
Construction of the approved weir for the recycling of process water has begun at the site and will result in an
expense to Carolina Sunrock of approximately $65,000.00, will the additional cost of this civil penalty benefit the
environment?
w thesunrockgroup.com

Thank you for your time and positive consideration in this matter. Please feel free to contact me if additional
information is required.
Sincerely,
Carolina Sunrock LLC
ony L. Sample, C.P.E.S.C.
Compliance Manager
Enclosures
[e-mail]
Phone: [phone]
Fax: [phone]

Carolina Sunrock LLC
North Raleigh Distribution Center
Cronological History
10/11/02
SPPP Plan Approved and Signed by Owner
09/00/04
Applied for Special Use Permit from Town of Wake Forest
10/19/04
Received Special Use Permit to modify site
03/25/05
Review SPCC Plan and PPP Plan — Added fuel tank to site, SPCC
Plan now Required
05/23/05
Applied for Wake County E&S Plan Approval
07/15/05
NCDWQ Stream Determination, required by County
11/04/05
Revised SPCC Plan and PPP Plan
12/22/05
NCDWQ Inspection— Inspector met with Tim Kopec
O1/03/05
NCDWQ Follow-up Inspection — Met with Tony Sample
01/04/06
Revised Site Plan for PPP Plan and other changes to PPP Plan
O1/09/06
Notice of Violation Received
O1/26/06
Completed Modification Request (& ATC request for weir) &
NOV Response
03/21/06
Stormwater Sample Taken
03/22-3/06
Sample analyzed
03/23/06
Met With Aisha Lau on Kittrell Distribution Center site
Asked about ATC — Didn't recall seeing application
03/24/06
Found Application on her Desk — had arrived 2/14/06
03/31/06
E-mail from Aisha requesting Clarification
04/03/06
E-mail response Sent to Aisha
06/02/06
Met with Aisha to go over application — Requested changes
06/06/06
Provided requested changes
07/26/06
Called Aisha to request status of application — left message
07/27/06
Called Aisha and left message — sent e-mail requesting status
07/31/06
Received Civil Penalty Assessment
08/03/06
Received ATC for Weir.

Pollution Prevention Plan
North Raleigh Distribution Center
Wake Forest, North Carolina
05/28/03 TLS
04/27/04 TLS
03/25/06 TLS
11/04/05 TLS
01/04/06 TLS
Prepared by:
Carolina Sunrock, LLC
1001 West B. Street
Butner, North Carolina 27509
May 2003

Spill Prevention, Control and
Countermeasure (SPCC) Plan
North Raleigh Concrete
Wake Forest, North Carolina
10/11/02 TLS
05/06/03 TLS
04/27/04 TLS
03/25/05 TLS
Prepared by:
Carolina Sunrock Corporation
1001 West B. Street
Butner, North Carolina 27509
June 2001

SPCC PLAN REVIEW AND EVALUATION
In accordance with 40 CFR Part 112.50), a review and evaluation of this SPCC Plan is conducted at least
once every three years. As a result if this review and evaluation, Carolina Sunrock Corporation will
amend the SPCC Plan within six months of the review to include more effective prevention and control
technology if: (1) such technology will significantly reduce the likelihood of a spill event from the
facility, and (2) if such technology has been field -proven at the time of review. Any amendment to the
SPCC Plan will be certified by a Registered Professional Engineer within six months after a change in the
facility design, construction, operation, or maintenance occurs which materially affects the facility's
potential for the discharge of oil into or upon the navigable waters of the United States or adjoining
shorelines.
Review Dates
1_ 10/I1/02
2. 5/6/03
3. OYIZ-7/c 'I
4, 03 zr0
5.
Sieoatare
' SPCC Plan amended and certified by a Registered Professional Engineer per 40 CFR Part I I2.3(d)
(not Requved — No 1320 gal. Tank)

Tony L. Sample
Carolina Sunrock, LLC
PO Box 25
Butner, NC 27509
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
August 30, 2006
SEP
RE: Request for Remission of Civil Penalty
Carolina Sunrock, LLC
North Raleigh Distribution Center (COC NCG 140328)
Case No. PC-2006-0008
Wake County
Dear Mr. Sample:
The Division of Water Quality has received your request for remission of civil penalty
dated August 24, 2006, with accompanying support information. Your request will be
presented to the Director of the Division of Water Quality and you will be notified of the
results.
Should you have any questions, please feel free to call Chuck Wakild with the DWQ
Raleigh Regional Office at [phone] or Priscilla Benson at [phone] ext. 360.
Sincerely,
�I
VA
Karen Higgins
NPS Assistance and Compliance Oversight Unit
cc: Chuck Wakild — DWQ Raleigh Regional Office Supervisor
Ron Boone — DWQ Raleigh Regional Office
NPS Assistance and Compliance Oversight Unit — File Copy
DWQ Central Files
tCuolin
Arra!!p
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.newaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone] I-877-623-6748
An Equal Opportunity/Affirmative Action Employer— 50°/6 Recycled/10% Post Consumer Paper

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC-2006-0008 County: Wake
Assessed Party: Carolina Sunrock, LLC
Permit No. (if applicable): NCG140000 Amount Assessed: $7,796.89
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission. Waiver of Right to an Administrative Hearing and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully pplied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
i/ (b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
_ (c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

STATE OF NORTH CAROLINA
COUNTY OF WAKE
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
CAROLINA SUNROCK, LLC )
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. PC-2006-0008
Having been assessed civil penalties totaling $ 7,796.89 for violation(s) as
set forth in the assessment document of the Director of the Division of Water Quality dated
July 27, 2006 , the undersigned, desiring to seek remission of the civil penalties, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate
that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within
thirty (30) days of receipt of the civil penalty assessment. No new evidence in support of a
remission request will be allowed after thirty (30) days from the receipt of the civil penalty
assessment.
This the Z day of 20 pG .
iJo,6oc z s'
TELEPHONE
�Z-

r
CAROLINA SUNROCK LLC
August 24, 2006
Ms Karen Higgins
NC Division of Water Quality
NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Assessment of Civil Penalties dated July 31, 2006
Carolina Sunrock LLC
North Raleigh Distribution Center
Case No. PC-2006-0008
Dear Ms Higgins,
Tony L. Sample, CPESC
Compliance Manager
PO Box 25 Butner, NC 27509
Carolina Sunrock LLC would respectfully request remission of the above referenced Assessment. We feel that the
violations were promptly abated and the potential for environmental damage was minimized and was never as high
as the civil penalty amount would suggest. Furthermore, the Notice of Violation on page 5 of 6, specifically pared
the concerns down to three primary issues for assessing the penalty, and the actual assessment had expanded
those three items into 13, half of the amount of the penalty was for paperwork violations and did not involve
potential environmental damage. The site visit that initiated this action was the first time this site had been
inspected, and the perception we have resulting from this inspection, the NOV and the Assessment, is that the
Division of Water Quality is more concerned in Citing Operators than helping prevent the pollution of our State
waters. We are committed to protecting the environment and doing what we can to prevent pollution, and we are
willing to work with the Department to do a better job, but lets all work together.
Carolina Sunrock was aware that something needed to be done to address the runoff at this site and we had been
working to address this potential problem for some time prior to the December 2005 inspection. I have attached a
Chronological History of our activities for this site to assist in convincing you of our positive actions toward
maintaining compliance within our Company. We have been in the plan ninglpermitting stage of operation since
2004 to correct deficiencies that we saw needed addressing at this site. An Authorization to Construct for our
recycling weir was finally received on August 3, 2006 after 193 days of review by the Department. We further admit
that we had a disorganized, incomplete Pollution Prevention Plan, but we did have a plan, we were making an effort
to comply with our Stormwater Permit.
Construction of the approved weir for the recycling of process water has begun at the site and will result in an
expense to Carolina Sunrock of approximately $65,000.00, will the additional cost of this civil penalty benefit the
environment?
www.thesunrockgrouip.com

Thank you for your time and positive consideration in this matter. Please feel free to contact me if additional
information is required.
Sincerely,
Carolina Sunrock LLC
ony L. Sample, C.P.E.S.C.
Compliance Manager
Enclosures
[e-mail]
Phone:[phone]
Fax:[phone]

Carolina Sunrock LLC
North Raleigh Distribution Center
Cronological History
10/11/02
SPPP Plan Approved and Signed by Owner
09/00/04
Applied for Special Use Permit from Town of Wake Forest
10/19/04
Received Special Use Permit to modify site
03/25/05
Review SPCC Plan and PPP Plan — Added fuel tank to site, SPCC
Plan now Required
05/23/05
Applied for Wake County E&S Plan Approval
07/15/05
NCDWQ Stream Determination, required by County
11/04/05
Revised SPCC Plan and PPP Plan
12/22/05
NCDWQ Inspection— Inspector met with Tim Kopec
O1/03/05
NCDWQ Follow-up Inspection— Met with Tony Sample
O1/04/06
Revised Site Plan for PPP Plan and other changes to PPP Plan
O1/09/06
Notice of Violation Received
O1/26/06
Completed Modification Request (& ATC request for weir) &
NOV Response
03/21/06
Stormwater Sample Taken
03/22-3/06
Sample analyzed
03/23/06
Met With Aisba Lau on Kittrell Distribution Center site
Asked about ATC — Didn't recall seeing application
03/24/06
Found Application on her Desk — had arrived 2/14/06
03/31/06
E-mail from Aisha requesting Clarification
04/03/06
E-mail response Sent to Aisha
06/02/06
Met with Aisha to go over application — Requested changes
06/06/06
Provided requested changes
07/26/06
Called Aisha to request status of application — left message
07/27/06
Called Aisha and left message — sent e-mail requesting status
07/31/06
Received Civil Penalty Assessment
08/03/06
Received ATC for Weir.

Pollution Prevention Plan
North Raleigh Distribution. Center
Wake Forest, North Carolina
05/28/03 TLS
04/27/04 TLS
03/25/06 TLS
11/04/05 TLS
01/04/06 TLS
Prepared by:
Carolina Sunrock, LLC
1001 West B. Street
Butner, North Carolina 27509
May 2003

�� nY r ti•
f s ;enl�i R,..f`�FFyLR':l°f ? it�„� lr �1}i_i. h iA:1i. `'.•� vii 41::
Spill Prevention, Control and
Countermeasure (SPCC) Plan
North Raleigh Concrete
Wake Forest, North Carolina
10/11/02 TLS
05/06/03 TLS
04/27/04 TLS
03/25/05 TLS
Prepared by:
Carolina Sunrock Corporation
1001 West B. Street
Butner, North Carolina 27509
June 2001

SPCC PLAN REVIEW AND EVALUATION
In accordance with 40 CFR Part It 2.5ft a review and evaluation of this SPCC Plan is conducted at least
once every three years. As a result if this review and evaluation, Carolina Sunrock Corporation will
amend the SPCC Plan within six months of the review to include more effective prevention and control
technology if: (1) such technology will significantly reduce the likelihood of a spill event from the
facility, and (2) if such technology has been field -proven at the time of review. Any amendment to the
SPCC Plan will be certified by a Registered Professional Engineer within six months after a change in the
facility design, construction, operation, or maintenance occurs which materially affects the facility's
potential for the discharge of oil into or upon the navigable waters of the United States or adjoining
shorelines.
Review Dates
1. 10/11/02
2. 5/6/03
3. f41Z-7/0y
4, 0 3 Z r 0
Signature
'r.6.,.
SPCC Plan amended and certified by a Registered Professional Engineer per 40 CFR Part I I2.3(d)
(not Required — No 1320 gal. Tank)

N
Q.
3
A
m
D
(b
rt
0
(n
rt
(A
(A
0
co
D
T
N
V '' ^^
)
rt
rt
h
sz
m
OO
Ln=
O
mm
m3
0
m
(b
co
(b
a
s
W00
.P.
0003
�
Ln
rt
+
' n
V /
mmm
(boor
rt
rt
rt
j
7
0
�O
T
y
T
r
CD
c�+
P."
a
V
n
m
N 3T
o0
\ \ H WY 1
Jai
CID
\ \N rI V)
�• • �p TomT^^ 9 z . ' � 73
O
fD (D to _/�' / \
a' CC)
��` v
I~-/ (7 / ;' '' i /� i l ., ci O 5
p 061, J
,..Z
►•� n i; „/�; \ti e' v / A? /� Q eA
Drp
p� (D o ZBZ\Fc
CAL / /: FT9T�B!/-('
wipo / ,r\•�`L Q- n
� c' •. , � j Ff ��. q(ytons _ - - - - - qi '1 7�
O I I L' N\ I S tz� Y ro
0 ;No Pot
r �� �' \ ` / '' � o /n \ . /�,o� \ - - \. • \ ,.,
ie6��ton r/ // N
CD
'� c+ / ✓'', / / - N Soo 1 u
N \
J++ ,\i '/ ` wu sue-00
\ l• /
000)
,j coo
t �
O�� 1 �.
� CnrD
Oo \
<+ O SZ
'I rd crtw r /, q
M--� (D Q _� / �l I w•" + _ ' I A�4 i A`\ F > : B� tea \ % / �Y �\y��(Jc (()
(n • l , I I ,ti I r / m / t, 'sac ti *� '' , F\ ,. �. ,y§,\ \ \ Tn / /
co
rD Q Cf)
�•1A
l76
• \ / f_ ♦ �Z/mac„
lap.
�.IC
/0) \ rl a
74
I�.•�'• / e C� w m 27 S NCO
/ O \
/ oVP7
o
C7 Y QM, 7 `�,°f'1J �� l - I I cI- Iml I ZI /;,
y 9y vv O o A 000Mrm �_mr+x
/-\103 a 0rnD m0000
�° 1, o Fnommo�f�-co
/ ?) �, x to Oxx{N»
mz
IN
:EW:. �(b
. \ +
➢�conm
m
(J to tjS` \
o
\� _ <oD�mz m,
v� o
C2 v
r
II rZ v>
�• co I'dr• •
iV ►ZCC•P!] W :'m,,��s tPo -n ��IQ1 htnp► r��,� Z�1 ro >D�7 cco a �2 P
C�
" \xx
D
=
��+0copA o
0� ��i rrI -1 O o00
00,0 ON (A O-u UI O mo o
cv-�i
cf)
o n CID k lD cn c)W o I `'W o
Ccn cc O nc � Z -j 'D CA �
vzCn r D � O _0 7u NON tz OC T`Z -1 m
<mm rto �N N N m mO m
,oo mz
CO 1aRINR m o M gg$ R ra CD III m u m c p y
cD ' -i O 7- U iNR• mi"NO Z 0
CiJO D
ill
Frl
0
to
CA
CA r-�
co
tv
\
�00
C7
IV
0
14 �o- riuu
z t� $
y"
� te R
9
up-
rYV
9
up-
rYV