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HomeMy WebLinkAboutNCG160085_COMPLETE FILE - HISTORICAL_20160727STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. w �� I 0 0 J DOC TYPE, 1�41-1ISTORICALFILE ❑ MONITORING REPORTS DOC DATE ❑ p� u I L 7 YYYYMMDD UH� July 22, 2016 Gary Perlmutter, M.Sc Environmental Specialist Division of Air Quality 1628 Mail Service Center Raleigh, NC 27609-1628 JUL 2 7 , lLp: NC DENR P,aieigh Rep^o,1a; ; RE: NPDES Stormwater Compliance Evaluation Inspection, COC No. NCG 160085 Dear Mr. Perlmutter, Lane Construction Corporation is in receipt of the NPDES Stormwater Compliance Evaluation Inspection dated June 28, 2016. Inspection point #4 was noted to have sediment buildup clogging the drain to the oil water separator. The sediment has been cleaned out, as requested. Please see the attached pictures 1 and 2. If I can be of further assistance, please call me at 828 782 1161. , Thank you, 4'�.,, LANE Greg Davis I Environmental Coordinator The Lane Construction Corporation 8205 Wilkinson Blvd. ICharlotte, NC 28214 ': GWDavis(cDlane construct. com (: 704.395.3264 1 7: 704.394.5354 1 o: 828.782.1161 1 www.laneconstruct.com Please consider the environment before printing. The Lane Construction Corporation 8205 Wilkinson Boulevard Charlotte, NC 28214 USA T704.394.8354 F704.394.5354 LaneConstruct.com An Equal Opportunity Employer M/F/D/V PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary June 30, 2016 Mr. Hal Byrd, Assistant Plant Manager The Lane Construction Company 3010 Gresham Lake Road Raleigh, NC 27615 Subject: Multimedia Compliance Inspection Lane (Gamer) Wake County Dear Permittee: Department of Environmental Quality staff conducted a multimedia compliance inspection of Lane (Garner) on June 20, 2016 for permitted and/or other activities administered by the following Divisions: Division of Air Division of Mineral . Division of Water Division of Waste Quality(DAQ) and Land Resources Resources (DWR) Management (pMLR) (DWG We hope that you have enjoyed the benefit of our initiative to provide a single inspector capable of handling multiple areas of environmental compliance at your facility. The results of each applicable inspection area and any associated response actions or necessary corrective measures are detailed in the Division specific areas of the attached report. If there are no notes or comments under a specific Division header, you may assume compliance with that particular Division's rules and regulations at the time of inspection. Should violations be noted in the attached report, you may receive separate enforcement related correspondence in addition to this report. If you have any questions regarding this multimedia inspection, please contact Gary Perlmutter at 919- 791-4200 or gary.perlmutter@ncdenr.gov. Thank you for your cooperation. cc: DAQ RRO Files DEMLR (DWR) RRO Stormwater Files Department of Environmental Quality, Raleigh Regional Office Website: Itttu://deq.nc.gov/ 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 7914200 Location: 3800 Barrett Drive. Raleigh, NC 27609 Fax: t919) 571-4718 a ��) PAT MCCRORY Covemor DONALD R. VAN DER VAART Secretory June,30, 2016 Hal Byrd, Assistant Plant Manager The Lane Construction Corporation 3010 Gresham Lake Rd Raleigh, NC 27615 Subject: NPDES Stormwater Compliance Evaluation Inspection Certificate of Coverage No. NCG160092 Lane (Garner) Wake County, North Carolina Dear Mr. Byrd: Staff from the Department of Environmental Quality (DEQ) conducted a stormwater inspection on June 20, 2016, as part of a multimedia inspection of your facility. The assistance provided by Mr. Greg Davis and Mr. Jamie Backus, during the"inspection was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: Certificate of Coverage (COC) No. NCG160082 under NPDES General Permit NCG160000 was issued to Lane (Garner) to discharge stormwater runoff to White Oak Creek (Austin Pond), a Class.C, NSW stream, in the Neuse River Basin. 2. The facility has developed and implemented a stormwater pollution prevention plan (SPPP). A review of the plan indicated that it included all components required by the general permit. 3. Semi-annual qualitative and analytical monitoring has been conducted at two stormwater discharge outfalls (SDOs), as required by the General Permit. However, some reports were missing and two exceedences were reported that were not followed by response actions, which are considered violations of permit conditions in your general permit. A Notice of Violation has been sent to you separately. 4. Both SDOs were observed and found accessible. 5. No separate wastewater discharges were observed. Raleigh Regional Office1628 Mail Service Center, Raleigh, North Carolina 27699-1628 Phone: 919-791-4200 / FAX: 919-571-4718 / Internet: fttp://portal.ncdenr.org/web/lr/ An Equal Opportunity \ Affirmative Action Employer — 50% Recycled \ 10%Post Consumer Paper Page 2 of 2 i Please respond in writing to DEQ Raleigh Regional Office regarding Item 3 within 60 days of receipt of this letter. If you have any questions regarding the attached report or any of the findings, please contact Gary Perlmutter at 919-791-4200 (or email: ary.perlmutter(2,ncdenr.govl. Sincerely /61 Gary Perlmutter Environmental Specialist NC Dept. of Environment Quality Division of Air Quality Raleigh Regional Office Enclosure: Compliance Evaluation Inspection Form cc: Central Files PRO SWP/Stormwater files Compliance Inspection Report Permit: NCG160082 Effective: 10/02/14 Expiration: 09/30/19 Owner: The Lane Construction Corporation SOC: Effective: Expiration: ' Facility: LANE (Gamer) County: Wake 1201 E Garner Rd Region: Raleigh Garner NC 27529 Contact Person: Jamie Backus - Title: Phone: 919-772-6366 Directions to Facility: System Classifications: Primary ORC: _ - Certification: Phone: Secondary ORC(s): On -Site Representative(s): , Corporate Responsible Official Greg Davis 704-395-3264 On -site representative Jamie Backus 919-772-6366 Related Permits: _ Inspection Date: 06/2012016 _EntryTime:- 09:30AM : _ Exit Time: 12:45PM Primary Inspector: Gary Perlmutter Phone: 919-791-4279 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge CDC Facility Status: Compliant ® Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCG160082 Owner •Facility: The Lane Construction Corporation Inspection Data: 06/20/2016 Inspection Type: Compliance Evaluation Reason for Visit Routine Inspection Summary On June 20, 2016, 1 (Gary Perlmutter, DAQ-RRO) visited Lane (Garner) for a multimedia inspection. There I met with Mr. Jamie Backus, Plant Supervisor, and Mr. Greg Davis, Environmental Coordinator. We first rewiewed permit stipulations and required records for complaince with General Stormwater Permit No. NCG160082, dated September 30, 2014. The SPPP was found to be dated 2014, to which Mr. Davis indicated that he is currently reviewing it as one of his tasks as the , Company's new Environmental Coordinator. The SPPP was fairly well organized, however some Qualitative and Analytical reports were found missing. Facility personnel contacted the analytical laboratory for the missing reports, of which they were e-mailed one report for samples collected in July 2015. Reports for the second half of 2012 and the first half of 2014 were still unaccounted for. The analytical report for sampling in December 2014 showed an exceedence of 109 TSS, and that for samples collected in December 2013 showed an exceedence of 329 mg/L TSS. Neither exceedence was followed up with TIER ONE investigation. Mr. Backus and Mr. Davis noted that moving forward they will plan to sample for the current Monitoring Period ending June 30, 2016, as rain is expected on Friday, June 24, 2016. During the tour all tanks were observed with secondary containment walls, in which Mr. Backus indicated are empited via pump (no valves or open-ended pipes were observed). Both outfall pipes were observed, and they appeared well maintained for easy sampling access. Page: 2 f Permit: NCG160082 Owner • Facility: The Lane Construction Corporation Inspection Date: 06/20/2016 Inspection Type: Compliance Evaluation Reason for Visit Routine Analytical Monitoring Has the facility conducted its Analytical monitoring? Yes No NA NE ❑®❑❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑ Comment: Analytical Reports missing for 2nd half of 2012 & 1 st half of 2014. No response actions taken for TSS exceedences in 2nd half of 2013 (329 mg/L) & 2nd half of 2014 (109 mq/L). Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? M ❑ ❑ ❑ # Were all outfalls observed during the inspection? Y ❑ ❑ ❑ # If the facility has representative outfall status, Is it properly documented by the Division? ❑ ®❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ ❑ Comment: Two outfalls were observed: SDO 1 and. SDO 2. which lie on ooDosite sides of the facilitv. The facility's Certificate of Coverage was observed with the recieving waters identified as White Oak Creek (Austin Pond). The pond is the receiving water for SDO 2 which appears to have no outflow, but is situated above an unnamed intermittent stream of White Oak Creek. SDO 1 lies above a slope that drains to White Oak Creek. The facility has no representative outfall Qualitative Monitoring - Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ M ❑ ❑ Comment: Qualitative Monitoring Reports missing for 2nd half of 2012, first and second half of 2014 Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? S ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ■ ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ®❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ®❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ®❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ®❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ®❑ ❑ ❑ # Does the facility provide and document Employee Training? 0 Cl ❑ ❑ # Does the Plan include a list of Responsible Party(s)? Y ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ®❑ ❑ Page: 3 Permit: NCG160082 Owner •Facility: The Lana Construction Corporation Inspection Date: 06/20/2016 Inspection Type: Compliance Evaluation Reason for Visit Routine Stormwater Pollution Prevention Plan Yes No NA NE # Does the Plan include a Stormwater Facility Inspection Program? 19 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ®❑ ❑ ❑ Comment: The facility's SPPP is being reviewd and revised by Company's new Environmental Coordinator, Greg Davis. at time of inspection. Page: 4 ��� NORTH CAROLINA DIVISION OF AIR QUALITY Inspection Report Date: 06/21/2016 Facility Data LANE (Garner) 1201 East Gamer Road Gamer, NC 27529 Lat: 35d 42.1080m Long: 78d 34.0140m . SIC: 2951 / Paving Mixtures And Blocks NAICS: 324121 / Asphalt Paving Mixture and Block Manufacturing LANE (Gamer) NC Facility ID 9200338 County/FIPS: Wake/183 Permit Data Permit 05747 / R14 Issued 1/10/2013 Expires 12/31/2017 Classification Synthetic Minor Permit Status Active Current Permit Application(s) None Contact Data Program Applicability SIP Facility Contact. Authorized Contact Technical Contact Jamie Backus Robert Spencer Greg Davis NSPS: Subpart I Plant Supervisor District Manager Environmental (919) 524-9152 (919) 876-4550 G6,p(dinator (73) 395-3264 Compliance Data Comments: Appeared to be in compliance" Inspection Date 06/20/2016 Inspector's Name Gary Perlmutter Inspector's Signature: /' Operating:Status_Operating. U Compliance Code Compliance - inspection / Date of Signature: 6- 6 Action Code FCE On -Site Inspection Result Compliance . Total Actnalnrniccinne in TnNWVRA R- TSP S02 NOX VOC CO PMIO *HAP 201 t v 1.20 15.86 5.20 0.9000 3.30 1.0000 56.90 -2006 4.80 15.37 7.50 4.20 12.00 3.00 550.00 Five Year Violation History: Date Letter Tvpe Rule Violated 10/18/2011 NOV Part 60 - NSPS Subpart I Hot Mix Asphalt Facilities Date [U] Test Results Test Method(s) Violation Resolution Date 11/08/2011 Source(s) Tested DIRECTIONS: From RRO take the behline east to I40 East toward Wilmington/Bensou. Take exit 303 for Jones Sausage Rd and turn right. Tom left on East Garner Rd. (SR 1004). Go north over I40 and facility will be approx. 1/2 mile on left (after the Martin Marietta Quarry). i .9200338 1nsocctio❑ Itcport P a g.P 2 . (11) FACILITY DESCRIPTION: LANE produces hot -mix asphalt. The LANE (Gamer) Plant is a parallel flow, drum -type Hot Mix Asphalt (HMA) plant. When operational, the plant typically has 3 employees on site and operates 40 hours/week. The facility started in 1985 and began production in 1989. The plant makes various mixes, dependent on the job requirements. Base mixes and binder mixes are produced, although several types of surface mixes constitute 60-65% of their operations. Aggregate mixes will vary, although a typical mix would be 25% stone, 33% regular screening, and 42% washed screening.. The plant does re -introduce the particles caught in the baghouse back into the mix. Safety notes: Standard PPE (steel toe shoes, hard hat, safety glasses) is required plus a reflective safety vest. (111) (IV) INSPECTION SUMMARY: On June 20, 2016, I (Gary Perlmutter), inspected the Lane asphalt facility in Gamer as part of a multimedia inspection. I met with Mr. Jamie Backus who is the foreman of the site and Mr. Greg Davis, the company's new Environmental Coordinator. We reviewed the permit conditions and required records — all seemed in order. We then toured the facility, where all equipment was seen running with only steam emissions observed from atop the asphalt silos.; Overall, the facility appeared well run from an air quality standpoint — further details follow. PERMITTED EMISSION SOURCES. Emission Emission Source Control Control System Source ID , Description ; System ID ! Description Portable Drum Mix Asphalt Plant (400 tons per hour maximum design production rate, 300 tons per hour [permitted production rate) consisting of: -__ ...._...._.. ES 5 " hot mix storage silo (200 ton capacity) with associated conveyor N/A N/A ES-6 I hot mix storage silo (200 ton capacity) with associated conveyor N/A i N/A S-1 A'. ) _...tlheat ES-2A natural gas/ No. 2 fuel oil/ No. 2 recycled fuel oil / No 4 fuel oil / No. 4 recycled fuel oil / No. 5 fuel oil / No. 5 recycled fuel oil-firedNSPS i rotary drum mix asphaltic concrete plant (100 mmBtu/hr maximum j input) ...-........ i Aggregate screen unit (5 feet by 12 feet) with six (6) associated I storage bms...._... ._ _.__I , CD IA' . _. �:.... N/A bagfilter (10,067 square feet of filterFE area) ' ...-._ Y .. N/�A ES-4A Recycled asphalt product (RAP) screen unit (4 feet by 8 feet) with three (3) associated storage bins ;� N/A + ES-7 Itruck loadout� _ _. N/A N/A ES 8 �j natural gas/No 2 fuel oil fired hot oil heater (2.20 million Btu per N/A N/A hour maximum heat input) -��-. _. __. --._..._. .... .. _ ..__... _. _._ .. _._ .....___.. _.._..... .._.I All equipment was verified and observed (V) SPECIFIC CONDITIONS AND LIMITATIONS: A, Al The Pennittee shall comply with NCAC, Subchapter 2D..0202, 2D .0506, 2D .0516 2D'.0521, 2D .0524 (40 CFR 60 Subpart I), 2D .0535, 2D .0540, 2D .0611, 2D .1100, 2D .1806, 2Q .0315, 2Q A317, 2Q .0�00 and 2Q 10711. Appeared to be in compliance — see below. y., A.2 PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal and submit the air pollution emission inventoryieport for the 2016 calendar year. Appeared to be in compliance — I reminded the facility personnel of this condition. w. A.3 PARTICULATE CONTROL REQUIREMENT - As'required by 15A NCAC 2D .0506 "Particulates from Hot'Mix Asphalt Plants,' a. Particulate matter emissions resulting from the operation of a hot mix asphalt plant shall not exceed allowable emission rates.. " b. Visible emissions from stacks or vents at a hot mix asphalt plant shall be < 20 % opacity averaged over six minutes. C. Fugitive dust emissions shall be controlled as required by 15A NCAC 2D .0540. it. Fugitive emissions for sources at a hot mix asphalt plant not covered elsewhere under this Rule shall'not exceed 20 9200338 Inspuction R c p o r t Pag3 percent opacity averaged over six minutes. e. All hot mix asphalt batch plants shall be equipped with a scavenger process dust control system for the drying, conveying, classifying, and mixing equipment. The scavenger process dust control system shall exhaust through a stack or vent and shall be operated and maintained in such a manner as to comply with the allowable particulate emission rate and opacity limit of this Rule. Appeared to be in compliance — no visible emissions other than steam were observed from the asphalt plant during the inspection. AA SULFUR DIOXIDE (S02) CONTROL REQUIREMENT -As required by 15A NCAC 2D .0516, S02 emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. Appeared to be in compliance — the facility runs only on natural gas for over three years according to Mr. Backus. Natural gas is inherently low in sulfur, so compliance is espected. A.5 VISIBLE EMISSIONS (VE) CONTROL REOUIREMENT - As required by 15A NCAC 2D .0521, VE from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six -minute period. Appeared to be in compliance — no VE other than steam were observed from the asphalt plant during the inspection. A.6 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS (NSPS)" - For the asphalt plant (ID No. ES -I A), the Permittee shall comply with NSPS as promulgated in 40 CFR 60, Subpart I, including Subpart A "General Provisions." a. NSPS Emissions Limitations - As required by 15A NCAC 2D .0524, the Permittee shall not discharge or cause the discharge into the atmosphere from any affected source any gases which: i. Contain particulate matter in excess of 90 mg/dscm (0.04 gr/dscf); or ii. Exhibit 20 percent opacity, or greater. b. Recordkeeping Requirement - As a result of the March 1, 2012 compliance test, the asphalt production shall not exceed 300 tons per hour. For each day of operation, the Permittee shall maintain records showing the total production in tons, the hours of operation, and the highest targeted hourly production rate for that day. Appeared to be in compliance.— no VE other than steam were observed from the asphalt plant during the inspection. I reviewed' the facility production records, which showed daily averages to be about 140 tons per day.- A.7 NOTIFICATION REOUBREMENT - As required by 15A NCAC 2D .0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify DAQ by the next business day. Appeared to be in compliance — Mr. Backus indicated that no such incidents have occurred. Mr. Backus added that if any upset were to occur, Company policy dictates to shut down the plant immediately. A.8 FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess VE beyond the property boundary. Appeared to be in compliance — no fugitive dust was observed leaving the property; no complaints are on file against the facility. A.9 FABRIC FILTER REQUIREMENTS - As required by 15A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance (I&M) Requirements - the Permittee shall perform at least an annual internal inspection of each bagfilter system. The Permittee shall perform periodic I&M as recommended by the equipment manufacturer. b. Recordkeeoing Requirements - The results of all inspections and any variance from manufacturer's recommendations shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook shall be kept on -site and made available to DAQ personnel upon request. Appeared to be in compliance — I reviewed the baghouse logbook and found it complete and up-to-date with entries made every 2-3 months. 9200338 Inspection Report --------------- Page 14 A.10 TOXIC AIRPOLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT -Pursuant to 15A NCAC 21) .1100 "Control of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration, the following permit limits shall not be exceeded (see permit for list). Appeared to be in compliance — compliance was determined during permit review. Provided the facility is properly run, compliance is assumed. The facility appeared well run and maintained from an air quality standpoint during the inspection. A.11 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A NCAC 21).1806, the Permittee shall prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary., Appeared to be in compliance — while mild asphalt odors were detected onsite during the inspection, no objectionable odors were detected outside the property. No complaints are on rile against the facility. A.12 LIMITATION TO AVOID 15A NCAC 20.0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility -wide emissions shall be less than the following: Pollutant Emission Limit (Tons per consecutive 12-month period) S02 100 CO 100 a. Operations Restrictions - the following restrictions shall apply: i. The amount of asphalt produced shall be less than 1,300,000 tons per consecutive. l2-month period. ii. The sulfur content of all fuels shall be limited to 0.5% sulfur by weight. iii. If multiple fuels are used, emissions should be determined using the sum of the individual emissions rates. b. Recordkeepine Requirements i. The Permittee shall record monthly and total annually the following: A.. The amount of asphalt produced in tons. ii. Fuel supplier certification shall be kept on -site and made available to DAQ personnel upon request.. c. Reporting Requirements - Within 30 days after each calendar year, the Permittee shall submit the following:. i. Monthly and 12-month totals for the previous 12-month period of: A. Amount of asphalt produced in tons. . B. S02 and CO emissions. Appeared to be in compliance — I reviewed facility production spreadsheets to find. them complete and up-to-date. with the current 12-month rolling average of 10,975 tons asphalt from May 2014 to May.2015. The facility only horns natural gas to operate the plant, although permitted to run on other fuels. I had reviewed the 2015 annual report, which was received on January 28, 2016 and contained the following totals: 9,256 tons asphalt produced; 0.60 tons CO and 0.27 tons SO: emitted. A.13 VENDOR SUPPLIED RECYCLED No(s)2: 4 and 5 FUEL OIL REQUIREMENTS - In accordance with Rule 2Q .0317, the Permittee is avoiding the applicability of Rule 2Q .0700 by using recycled fuels which are equivalent to their virgin. counterparts. The Permittee is allowed to use the recycled fuel oil(s) supplied by a DAQ-approved vendor. Appeared to be in compliance — The facility is not using recycled fuel oil at this time and has not for over three years.. The previous inspection report notes: "The last delivery of No. 4 fuel oil was December 4, 2013 for 6,743 gallons.!, facility maintains copies of the fuel certifications. A.14 15A NCAC 20.0700 ARSENIC TPER REVIEW. This stipulation is a statement that the TPER for arsenic is under review. Once the review is completed, and if the current threshold is changed then the facility may have to show compliance with the new level. Appeared to be in compliance — the previous inspection report notes that the review process is now complete and that this stipulation will be removed in the next permit revision.:. A.15 TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT.- Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the permit listed toxic air pollutants (TAPS), the Permittee has made a demonstration that facility -wide actual emissions do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711. The facility shall be operated and maintained in such a manner that emissions of any listed TAPS from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 2Q .0711. Appeared to be in compliance — the facility appeared well run and maintained during the inspection; compliance is assumed. �_ ....._.__. p cc tion _.....__)? __ t' t 9_ 033 Intl to �___ Paac 15 (VI) GENERAL PERMIT CONDITIONS: B.5 REPORTING REQUIREMENT - Any changes that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ. Appeared to be in compliance — Mr. Backus and Mr. Davis said that no such changes have been made nor are any planned. B.14 PERMIT RETENTION REQUIREMENT - The Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site. Appeared to be in compliance — Mr. Backus presented a copy of Air Permit No. 057471114 during the inspection. B.15 CLEAN AIR ACT SECTION 112(r) REOUIREMENTS - Pursuant to 15A NCAC 2D .2100. "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. Not Applicable — the facility is not subject to the 112(r) rule. (VII) INSIGNICANT / EXEMPT SOURCES: Source Exem lion Re ulation Source of �TAPS�� Source of Title V Pollutants. i IS-1 - liquid asphalt cement tank 2Q 0102 (c)(1)(L)(xu) (3Q000 gallon capacity) Yes Yes ; IS-2 - anti -strip additive tank 2Q.0102(c)(1)(L)(xii) Q,500 gallon capacity) Yes Yes _ _._._.. IS-9 - fuel oil storage tank i ,0102 c 1)()O D r t (20,000 gallon capacity)_. ZQ.:._ O( Yes i Yes ! i IS-10 - fuel oil storage tank ( 2Q 0102 (c)(1)(D)(r) (20,000'gallon capacity) Yes if Yes All tanks were observed onsite; no additional insignificant / exempt sources were observed during the inspection. (VHI) EMISSIONS INVENTORY REVIEW: Between emission inventory years 2006 and 2011, nearly all criteria pollutants plus the highest HAP emissions have decreased.. Only S02 emissions had increased, but not significantly at 3.2%. Per Yuki Parham's review of the 2011 emissions inventory: "Corrected tetrachlorodibenzo p-dioxin emissions to 0 from 37 lbs/yr on July 25, 2013. It was supposed to be 3. 75e-09. " (IX) PERFORMANCE TEST REVIEW: A review of DAQ files revealed the following testing: • March 1, 2012 - the asphalt plant was tested by Methods 5 and 9 for NSPS Subpart I compliance. Yuki Purham observed the test. Results of 0% opacity average VE demonstrated compliance. • June 26, 2008 — the asphalt plant was tested by Method 9 for NSPS Subpart I, for the use of No. 4 recycled fuel oil. Matt Mahler observed the test. Results of 2.5% opacity average VE demonstrated compliance. The current permit does not have a testing requirement. (X) COMPLIANCE HISTORY: A review of DAQ files revealed the following permit violations by the facility: • October 18, 2011— an NOV was issued for a late report. • June 30, 2010 - an NOV was issued for failure to maintain the facility (B.6) and for failure to maintain production recordkeeping. All violations have been resolved. (XI) CONCLUSIONS/RECOMMENDATIONS: At the time of the inspection, LANE (Gamer) appeared to be in compliance with its air permit. I recommend to inspect the facility again next year. LANE October 9, 2014 NCDENR/DEMLR Attn: Dave Parnell 1628 Mail Service Center Raleigh, NC 27699-162 Re: Notice of Deficiency; NOD-2014-PC-0138 LANE (West Raleigh) Dear Mr. Parnell, V gly, � OCT 1 5 2014 NC DENR Raleigh Regional office This letter is to address the deficiency noted in your letter, which we received September 12, 2014. The SWPPP and subsequently, the site map were updated per your department's recommendations. The map now depicts the recycled asphalt on and over the property boundary. Personnel on site are aware of the change made to the SWPPP. Currently, we are working diligently towards an agreement with the City of Raleigh regarding the RAP issue. Should you have any further questions feel free to contact me at 704-395-3264. Sincerely, Urcus W ;Hac ler Environmental Coordinator Cc: GAW MRH DJE The Lane Construction Corporation 3010 Gresham Lake Road Raleigh, NC 27615 USA T 919.876.4550 r 919.878.0794 LaneConstruct.com An Equal Opportunity Employer M/F/D/V PWA NC® DdR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary July 10, 2014 Mr. Marcus W. Hackler LANE Construction Corporation 8205 Wilkerson Blvd Charlotte, NC 28214 Subject: NOT ICE OF DEFICIENCY: PLOD-2014-PC-" IQ LANE West Raleigh NPDES STORMWATER PERMIT NCG160085 Wake County Dear Mr. Hackler: On June 26, 2014, Dave Parnell, of the Raleigh Regional Office of the North Carolina Division of Energy, Mineral and Land Resources (DEMLR), conducted a compliance evaluation inspection (CEI) at the above referenced facility. The site lies in the watershed of an unnamed tributary (UT) to Richland Creek, Class C, NSW waters, which lies in the Neuse River Basin. The following observations were noted during the NCG160085 DEMLR inspection: This facility is an asphalt production facility, which does not conduct vehicle maintenance on site. Thank you for your assistance during the inspection, it was appreciated. The inspection began in the operations center, where a thorough review of the Stormwater Pollution Prevention Plan (SPPP); as well as, the qualitative and analytical monitoring results, was conducted. Analytical and Qualitative monitoring data were reviewed and found to be in order and compliant with the NPDES Stormwater Permit. Following the monitoring data review, all secondary containment, drainage patterns and the Stormwater Discharge Outfall (SDO) were observed. The entire production site flows to one outfall near the entrance to the facility. Mr. Parnell discussed with you the sample location and it was agreed that this is the proper location for your monitoring. The following deficiencies discovered during the inspection require your attention: 1. The SPPP requires that your site plan accurately depict your site. Your site plan did not accurately depict the location of production material (recycled asphalt), which has encroached on the property to the east of your facility. Division of Energy, Mineral, and Land Resources Energy Section • Geological Survey Section - Land Quality Section 1612 Mail Service Center, Raleigh, Norlh Carolina 27699-1612.919-707-9200 / FAX: 919-715-8801 512 North Salisbury Street, Raleigh, Norlh Carolina 27604 • Internet: http://portal.ncdenr.orgtweb/Ir/ An Equal Opportunity \ Affirmative Acton Employer — 50% Recycled \ 10% Post Consumer Paper Requested Response: You are directed to respond to this letter in writing to DEMLR at the address provided below within 30 days of receipt of this letter addressing the following: 1. Update the Stormwater Pollution Prevention Plan (SPPP) to include an updated site plan that accurately depicts the location of your production material. Address any encroachment issues with the adjacent property owner. Removal of the material and restoration of the adjacent area to ithe original landscape conditions is an option, as well. Please obtain all permits required prior to beginning removal of the material and restoration of the site. 2. Update the SPPP to accurately reflect any new Stormwater. Discharge Outfalls that have resulted from the encroachment of the production materials. Please respond to: Dave Parnell NCDENR/DEMLR Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-162 Should you have questions regarding these matters, please contact Dave Parnell at (919) 791- 4200 or david.parnell@ncdenr.gov. Sincerely, L. Holley, Jr.!PE, CPESC mal Engineer gh Regional Office cc: Stormwater Permitting Program Files - with attachment, DEMLR Raleigh Regional Office Files - with attachment DWR Raleigh Regional Office Files - (Attention: Cherri Smith) - with attachment Office of the Raleigh City Attorney, One Exchange Plaza Suite 1020, Raleigh, NC 27601 (Attention: Dan McLawhorn, Associate City Attorney) - with attachment NCDENR North Carolina Department of Environment and Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Governor Director November 30, 2012 Robert Spencer The LANE Construction Corp 3010 Gresham Lake Rd Raleigh, NC 27605 --------------------- DEC - 5 2012 u; No Secretary Subject: NPDES General Permit NCG160000 Certificate of Coverage NCG 160085 LANE (West Raleigh) Formerly Rea Contracting (West Raleigh 081) Wake County Dear Mr. Spencer: Division personnel received your request to revise your stornlwater permit Certificate of Coverage to accurately reflect your new company and facility name. Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency. If you have any questions, please contact the Stormwater Permitting Unit at 919-807-6300. Sincerely, ORIGINAL SIGNED W KEN PICKLE for Charles Wakild, P.E. cc: Raleigh Regional Office Central Files Stormwater Permitting Unit Wetlands and Stormwater Branch 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919807-63001 FAX: 919807-64941 Customer Service. 1877-623-6748 Internet: www.ncwaterquality.org An Equal Opportwtity 14n,onalive Action Emplover One NorthCarolina JVaturally STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG160000 CERTIFICATE OF COVERAGE No. NCG 160085 SfORMWATER DISCHARGE'S 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, The LANE Construction Corp is hereby authorized to discharge stormwater from a facility located at LANE (West Raleigh) 5801 Chapel Hill Rd Raleigh Wake County to receiving waters designated as a UT to Richland Creek, a class C NSW, waters in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111, IV, V and VI of General Permit No. NCG160000 as attached. This certificate of coverage shall become effective November 30, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 30, 2012. for ORIGINAL SIGNED W KEN PICKLE Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission s�® MC®ENR North Carolina Department of Environment'and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director December 4, 2009 �In fU DEC — Marcus Hackler .., Rea Contracting, A Division of The Lane Construction Corp. - 8205 Wilkinson Blvd. FOft'" Charlotte, NC 28214-7006 Dear Mr. Hackler: Dee Freeman Secretary 9 2009 Subject: NPDES General Permit NCG160000 Certificate of Coverage NCG 160085 Rea Contracting (West Raleigh) Formerly Rea Contracting, LLC Wake County On October 1, 2009, division personnel received your request to revise your stormwater permit Certificate of Coverage to accurately include your new company name. Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency. If you have any questions, please contact the Stormwater Permitting Unit at 919-807-6303. Sincerely, p Coleen H. Sullins cc: DWQ Central Files Raleigh Regional Office Stormwater Permitting Unit Wake County Wetlands and Stormwater Branch 1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Location: 512 N. Salisbury St. Raleigh, North Camlina 27604 Phone: 919-807.63001 FAX: 919-807-64941 Customer Service: 1-877-623-6748 Internet: www.nmaterquality.org One NorthCarolina An Equal Opportunity 1 Affirmative Action Employer STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAND NATURAL RESOURCES DIVISION OF WAFER QUALITY GENERAL PERMIT NO NCG160000 CERTIFICATE OF COVERAGE No. NCG160085 STORMWATER 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, Rea Contracting, A Division of The.Lane Construction Corp. is hereby authorized to discharge stormwater from a facility located at Rea Contracting (West Raleigh) 5801 New Chapel Road Raleigh Wake County to receiving waters designated as a UT to Richland Creek, a class C NSW water in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V and VI of General Permit No. NCG 160000 as attached. This certificate of coverage shall become effective December 4, 2009. This Certificate of Coverage shall remain in effect for the duration of theGeneralPermit. Signed this day December 4, 2009. ✓ Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission a State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan. W. Klimek, P.E., Director NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES December 19, 2003 Mr. Gene Mills Rea Contracting, LLC. 8205 Wilkinson Boulevard Charlotte, North Carolina 28214-7006 Subject: Ni Permit Modification - Name/Ownership Change Permit NCG160085 Rea Contracting LLC - West Raleigh 081 (Formerly Rea Construction Company) Wake County Dear Mr. Mills: In accordance with your request received November 10, 2003, the Division is forwarding the subject permit modification. This modification documents the change in name/ownership at the subject facility. All other terms and conditions in the original permit remain unchanged and in full effect. This permit modification is issued under the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit modification are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be a written petition conforming to Chapter 150B of the North Carolina General Statutes, filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demand is made, this decision shall be final and binding. This permit does not affect the legal requirement to obtain other permits which may be required by the Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local government permit that may be required. If you have any questions concerning this permit, please contact Valery Stephens at the telephone number or address listed below. cc: Central Files Raleigh Regional Office, Water Quality Section NPDES Unit 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Sincerely, ra W. Klimek, P.E. 919 733-5083, extension 520 (fax) 919 733-0719 VISIT Us ON THE INTERNET @ http://h20.enr.state,nc.us/ Valery.Stephens®ncmail.net it STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG160000 CERTIFICATE OF COVERAGE No. NCG160085 STORMWATER 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, Rea Contracting LLC. is hereby authorized to discharge stormwater from a facility located at Rea Contracting LLC — West Raleigh 081 5801 E Chapel Hill Road Raleigh Wake County to receiving waters designated as unnamed tributary to Richland Creek, a class C NSW water in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG160000 as attached. This certificate of coverage shall become effective December 19, 2003. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day December 19, 2003. l�py Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary Kerr T. Stevens, Director July 27. 1999 GENE MILLS REA CONSTRUCTION COMPANY-W. RALEIGH P.O. BOX 32487 CHARLOTTE, NC 28232 Dear Permittee: I 1� • NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Reissue - NPDES Stormwater Permit Rea Construction Company-W. Raleigh COC Number NCG 160085 Wake County In response to your renewal application for continued coverage under general permit NCG160000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: * A copy of general stormwater permit NCG160000 * A Stormwater Pollution Prevention Plan (SPPP) Certification Form. Completion of this form is required to certify that you have developed and implemented the SPPP as per the conditions of the permit. This form must be completed and returned to the Division within 30 days of receipt of this letter. DO NOT SEND the SPPP with the signed form. * Five copies of the Analytical Monitoring form and five copies of the Qualitative Monitoring form * A copy of a Technical Bulletin for the general permit which outlines changes in the permit, key requirements, and addresses frequently asked questions * A Certificate of Coverage Your coverage under this general permit is not transferable except after notice to DWQ. The Division 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 DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Tony Evans of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 584 Sincerely, for Kerr T. Stevens cc: Central Files Stormwater and General permits Unit Files Raleigh Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 Fax 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG160000 CERTIFICATE OF COVERAGE No. NCG160085 STORMWATER 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, REA CONSTRUCTION COMPANY-W. RALEIGH is hereby authorized to discharge stormwater from a facility located at REA CONSTRUCTION COMPANY-W. RALEIGH 5801 E CHAPEL HILL RD RALEIGH ► &WINxK611111" to receiving waters designated as a UT of Richland Creek 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. NCG160000 as attached. This certificate of coverage shall become effective August 1, 1999. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day July 27, 1999. for Kerr T. Stevens, Director Division of Water Quality By Authority of the Environmental Management Commission State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director June 30, 1995 Paul Schulz Rea Construction Co -Raleigh P.O. Box 32487 Charlotte, NC 28232 01)41 li<if ETCH 1 i :Iol FICF Subject: General Permit No. NCG160000 Rea Construction Co -Raleigh COC NCG160085 Wake County Dear Paul Schulz: In accordance with your application for discharge permit received on May 4, 1995, 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 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management. The Division of Environmental Management 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 Environmental Management 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 question concerning this permit, please contact MR. ANTONIO EVANS at telephone number 919/733-5083. Sincerely, Original Signed By Coleen H. Sullins A. Preston Howard, Jr. P.E. cc: Raleigh Regional Office P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 FAX 919-733-2496 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT GENERAL PERMIT NO, NCG160000 CERTIFICATE OF COVERAGE No. NCG160085 STORMW ATER 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, Rea Construction Co. is hereby authorized to discharge stormwater from a facility located at Rea Construction Co. 5801 E. Chapel Hill Road Raleigh, NC Wake County to receiving waters designated as an unnamed tributary to Richland Creek in the Neuse River Basin, Class C, NSW in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of General Permit No. NCGI60000 as attached. This certificate of coverage shall become effective June 30, 1995. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day June 30, 1995. Original Signed BY Coleen H- Sullins A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission REST/ ' � / !/ / / `✓— r .ORES H A c"_ AR �O ^1 �s fib ..� v � �\ �1� i '. ii '� •i'\ I � vJ �� \\^\��, � ,-�� .--1v��%�' •� /: / / J r �J�\ / �� C, �, Cem"_ �Y i. ss64 L/—'�!`(�' IIIi W- Ij \ .�I 39\. adRTi0++2r5 50 n. 4730 g\\1.\63 We tover�.�'•/� Cem SOLrTy� I /' �• ��� i ,i� i �✓ IoR lye Z '^:<96 -,� �I \`, :,ti1101i II w-BN ✓si 'i/� I. - I_.ivyi. IYQ I I / 1315 / • Y �A I! 39 h 3, ,' ����� ��91 t�Ali� II/� •' / ��s ��� Q / < \ NWt u h• A - - VAIIi 1 _ _ J0htt'5 l c S / :tn� ✓ ..Fa Q , Su�sln� II •�"a. � � �. ! � �l� /��� a��� .i/� low F,*A o NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary October 22, 2010 Mr. Dan Carmichael Plant Foreman Rea Contracting, LLC 5801 Chapel Hill Rd Raleigh, INC 27607 Subject: Compliance Evaluation Inspection Rea Contracting, LLC NCG 160085 Wake County Dear Mr. Carmichael: On September 15, 2010, a compliance evaluation inspection (CEI) was conducted at the subject facility. The assistance of you and Mr. Marcus Hackler, Environmental Coordinator was greatly appreciated. This inspection was conducted to determine your compliance with the subject NPDES stormwater general permit. The following observations were noted during the inspection: SITE DESCRIPTION The Rea Contracting, LLC West Raleigh site at 5801 E Chapel Hill Road in Raleigh, NC is conducting asphalt production. The site contains 7.27 acres of drainage, including 5 of which is pervious and 1.37 impervious. There is currently one outfall that is being inspected and monitored. INSPECTION SUMMARY a) The Stormwater Pollution Prevention Plan (SP3) was available and reviewed during the inspection. The Plan did not include a required USGS map; however, by September 16, 2010, a copy of the USGS that was inserted into the SP3 was received by our office. b) The singular outfall is located at the driveway entrance to the site and flows to an unnamed tributary of Walnut Creek. c) Qualitative and Analytical Monitoring have been conducted as required by the permit. An additional check dam was installed as a result of a Tier 1 exceedance. North Carolina Division of Water Duality Raleigh Regional Office Surface Water Protection Phone (919) 7914200 Internet: w nmaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 788-7159 An Equal Opponunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper One NorthCarolina — �7Vatr�rn/!J Customer Service 877-623-6748 .jpis Rea Contracting = West'Raleigh` NCG160085 j+ a ..-• Page 2 of 2 d) During the site visit, inspectors identified a second outfall (ditch) discharging into the stream (UT of Walnut Creek). DWQ requires analytical and qualitative monitoring of each stormwater outfall as specified in the Permit. Please add this outfall location to your Stormwater Pollution Prevention Plan and begin monitoring at this location. If you have any questions regarding the attached report or any of the findings, please contact me at 919-791-4200 or natalie.land ry(a)ncdenr.00v. Sincerely, Natalie Landry Environmental Specialist Surface Water Protection cc: RRO-SWP File DWQ Stormwater Permitting Unit Central Files Permit: NCG160085 SOC: County: Wake Region: Raleigh Compliance Inspection Report Effective: 10/01/09 Expiration: 09/30/14 Effective: Expiration: Contact Person: Gene Mills Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): 24 hour contact name Related Permits: Dan Carmichael Title: Certification: Owner: Rea Contracting LLC Facility: Rea Contracting -West Raleigh 081 5801 E Chapel Hill Rd Raleigh NC 27607 Phone:704-394-8354 Phone: Phone: Inspection Date: 09/15/2010 Entry Time: 11:05 AM Exit Time: 12:05 PM Primary Inspector: Natalie Landry Phone: 919-791-4200 Secondary Inspector(s): Mandy Hall Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge COC Facility Status: ■ Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) c Page:1 Permit: NCG160085 Owner • Facility: Rea Contracting LLC Inspection Date: 09/15/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Visited site on 08/26/2010 to investigate a complaint. Page:2 Permit: NCG160085 Owner - Facility: Rea Contracting LLC Inspection Date: 09/15/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ■ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ■ ❑ Cl ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ ❑ ❑ # Does the facility provide and document Employee Training? ■ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: Annual reviews and/or updates of the Plan are documented on the Facility Inspection Sheets. Suggested to Mr. Heckler to add a summary page near the front of the Plan to document such reviews and/or changes. Facility is inspected by personnel monthly. Plan was missing USGS Map; however, Mr. Hackler indicated by email on 09/16/2010, that a map had been added. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: N/A Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: Extra check dams installed as a result of high TSS result. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ Cl ❑ # Were all outfalls observed during the inspection? ■ ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑ Page: 3 Permit: NCG160085 Owner • Facility: Rea Contracting LLC Inspection Date: 09/1512010 Inspection Type: Compliance Evaluation # Has the facility evaluated all illicit (non stormwater) discharges? Comment: One SDO on -site. Reviewed with Mr. Hackler and Mr. Carmichael the need to sample discharge flowing under product pile. Permit expires 10/30/14. Reason for Visit: Routine ■ 0 0 11 Page:4 Parnell, David From: Holley, John Sent: Wednesday, June 18, 2014 1:48 PM To: Bennett, Bradley; Parnell, David Cc: Pickle, Ken Subject: RE: Lane Asphalt Dave, please check with Danny to see if there has been any activity on this matter through DWR. If not, it sounds like we need to follow-up with the city to be clear on the details going in, and we need to investigate the site for compliance with their general permit. Please advise. I From: Bennett, Bradley Sent: Wednesday, June 18, 2014 1:34 PM To: Parnell, David; Holley, John Cc: Pickle, Ken Subject: FW: Lane Asphalt Dave, John, See emails below. May want to talk with Danny. Im Bradley Bennett ur5 '-/xV h CVO Stormwater Permitting Program Phone: (919) 807-6378 NC Division of Energy, Mineral and Land Resources Fax: (919) 807-6494 1612 Mail Service Center Email: bradlev.bennett(a)ncdenr.00v Raleigh, NC 27699-1612 Web: http://portal.ncdenr.org/web/Ir/stormwater Email correspondence to and from this address may be subject to public records laws From: Pickle, Ken Sent: Wednesday, June 18, 2014 1:26 PM To: Bennett, Bradley Cc: Smith, Danny Subject: FW: Lane Asphalt Bradley - - FYI. potential participation may be required by DEMLR SPP. Please see attached email from Dan McLawhorn, COR. Apparently my email yesterday to Mark Senior and Pete Duffy concerns the same site. Yesterday I just reported on our available permitting records for an NCG16 permittee, Lane Construction. • Not sure who the original complainer was, or what is the full scope of the issue. • I don't know if Danny Smith is in the lead now (or if Dan McL just thinks he is), but we may be involved potentially. Sounds like COR started out to investigate a complaint, but that RRO DWR may be following up on it? • Dan McL. asserts that there is asphalt in the creek; • And that there are several violations of the stormwater permit coverage under NCG16. • Dan McL. also asserts that Lane has stockpiled material on COR property without COR permission. And that this unauthorized trespass (storing material on COR property) was the cause of the permit violations. 1 Ken Pickle Environmental Engineer NCDENR I DEMLR I Stormwater Permitting Program 1612 Mail Service Center, Raleigh, NC 27699-1612 512 N. Salisbury St, Raleigh, NC 27604 Phone: (919) 807-6376 Fax: (919) 807-6494 Email: ken.pickle@ncdenr.gov Website: http://p6rtal.ncdenr.org/web/Ir/stormwater ** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulations.** -----Original Message----- , From: McLawhorn, Dan[mailto:Dan.MCLawhorn(@raleighnc.goy] Sent: Wednesday, June 18, 2014 12:36 PM To: Smith, Danny; Pickle, Ken Cc: Senior, Mark Subject: Lane Asphalt Danny, It appears to me that Lane is in violation of its Stormwater General permit for several reasons. Those violations arise because it stored uncovered materials subject to Stormwater controls in an area off its property which could not have been included in its site plan. That property belongs to Raleigh which has not given permission to any owner of the facility to use its property. The overflow of its storage pile resulted in asphalt also being in the adjacent creek. These facts should be documented in the facility's onsite records, available to the Department but not the City. In addition, aerial photos on the real property database for Wake County document the trespassing pile outside the permit holder's site. Please let me know how the City can assist in the investigation. Dan McLawhorn Sent from my iPhone z V Ld- I i G-M `va" Cw,micl a e� Compliance Inspection Report Permit: NCG160085 Effective: 10/01/09 Expiration: 09/30/14 SOC: Effective: Expiration: County: Wake Region: Raleigh COL>r-01 I Ch -_ LQ_ Contact Person: Gene-MM9— `t71� YITGitI-e: Directions to Facility: y�YbLJI'¢— System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Owner: Rea Contracting LLC Facility: Rea Contracting -West Raleigh 081 5801 E Chapel Hill Rd Raleigh INC 27607 Phone: 9'64394-835rL Certification: Phone: Inspection Date: 08/26/2010 Entry Time: 01:00 PM Exit Time: 02:00 PM Primary Inspector: Natalie Landry Secondary Inspector(s): Mandy Hall Reason for Inspection: Complaint Inspection Type: Complaint Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge COC Facility Status: ❑ Compliant ❑ Not Compliant Question Areas: E Storm Water (See attachment summary). N C�US I Cr �`QrC , Phone:919-791-4200 Phone: Page: 1 Permit: NCG160085 Owner - Facility: Rea Contracting LLC Inspection Date: 08/26/2010 Inspection Type: Complaint Reason for Visit: Complaint Inspection Summary: Groundwater seepage from product piles observed and iron bacteria precipate observed in groundwater. FES drain pipe leaving site that catches runoff from piles should be added as SDO. Page:2 Permit: NCG160085 Owner - Facility: Rea Contracting LLC Inspection Date: 08/26/2010 Inspection Type: Complaint Reason for Visit: Complaint Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ Cl # Does the Plan.include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? n n In In # Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ Cl # Does the facility provide all necessary secondary containment? In In ❑ ❑ # Does the Plan include a BMP summary? ❑ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? In In In In Has the Stormwater Pollution Prevention Plan been implemented? ❑ n ❑ n Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ n n n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑ ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ ❑ # Were all outfalls observed during the inspection? ❑ n n ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑ ❑ Comment: Page: 3 Complaint and Compliance Inspection Form (updated 12/14) Page 1 Complainant Contact Info Complaint DateBTims of Call DWO RO Project Typa County „�(L,� Inspection Typa Inspector L M River Basin Inspection Date I 7-.-es- Stream Name Site Name )�'LA Class OwnerBContact Info Directions to Site Vlolatlons/Concerns (check all that apply) Stream Wetland Standards Riparian Buffer Buffer impacts (If) Buffer impacts (sq. ft) Does the Inspection merit an NOV? ❑wg ❑i c a4, -Iua k�z2g 76�»-) Le a ew w Gr' J S D o Complaint and Compliance Inspection Form Page Construction Stormwater NPDES NCGO10000 Land disturbance due to construction/development? Site is over 1 acre? Does the site have an approved/signed E&SC plan if so, by what agency)? Location/address: On -site respresentative available during inspection? Contact/phone Info: Does Land Quality or local program have an inspection report available for review? Record Keeping: Is a rain gauge present on site (at the time of inspection)? Is rain gauge data measured and recorded? Record data from past 14 days below: Week 1 Date: Amount: Week 2 Date: Amount: Are inspection records of E&SC BMPs complete and available on request? Is water quality at outfalls monitored and recorded? Impacts: Sediment range and depth (average to maximum): Turbidity/? Linear feet of stream impacted Other/Photo Documentation (label photos): 1. Impacted water 2. sedimentation depth 3. E&SC measures (BMPs) 4. un-impacted upstream waters Attach map/plan of site and where photos were taken Does the Inspection merit an NOV? ❑rea El No Date of Inspection and County_ Name of Inspector and RO Site name, owner name and contact Stream name and classification Rea 0 100 200 400 Feel Field Value PIN 0784212788 Real Estate ID 0082660 Map Name 078417 Owner LANE CONSTRUCTION CORPTHE Mailing Address 1 TAX DEPARTMENT Mailing Address 2 90 FIELDSTONE CT Mailing Address 3 CHESHIRE CT 06410-1212 Deed Book 13790 Deed Page 0418 Deed Date 12/10/2009 Deeded Acreage 6.15 Assessed Building Value $147,888.00 Assessed Land Value $863,621.00 Total Assessed Value $1,011,509.00 Billing Class CORPORATE LISTING Property Description PROP OF REA CONSTRUCTION CO Heated Area 2560 Site Address 5801 CHAPEL HILL RD City Raleigh Township MEREDITH Year Built 1986 Total Sale Price $60000.00 Sale Date 1/1/1972 12:00:00 AM Type and Use Typical Office Design Style Conventional Land Class COMMERCIAL Old Parcel Number 520-00000-0111 WAKE COUNTY \IINIII 1A .11 From: Smith, Danny I Sent: Monday, August 23, 2010 3:09 PM To: Powell, Jeanette Cc: Hall, Mandy Subject: RE: Councilor Crowder request on asphalt plant and concrete plant Attachments: image001.jpg Hey Jea nette, We have conducted a file review and do not have any current/recent compliance issues in our files regarding the subject facilities. We are planning to conduct a site visit/inspection this week. We will let you know our findings. (By the way, thanks for the up date on the code changes regarding monitoring.) Xb See ya r cc r PCG'(�— � �{,;o danny ca — 'D6r-" m4c,,Ls-3Z�f M email has changed to dannv.smith@ncdenrgov Nao�te (L 2� 3 * *E-mail correspondence to and from this address maybe subject to the North Carolina Public Records Law and maybe disclosed to third parties. From: Powell, Jeanette [mailto:Jeanette.Powell@raleighnc.gov] Sent: Monday, August 23, 2010 12:06 PM To: Smith, Danny Subject: FW: Councilor Crowder request on asphalt plant and concrete plant Hi Danny, A City Council member raised concerns over an asphalt plant and a concrete plant on the west side (see attached map). I am sending an inspector out to investigate, but it sounds like most of the issues raised (see below) are going to fall under the NPDES permit. Have you guys inspected or taken any enforcement action against these two sites? Thanks, (��, Powell, CPESC, CPSWQ, CESSWI Stormwater Inspections Manager Stormwater Utility Division 9PJeanette n �' Public Works Department Office: (919) 516-2837 Fax: (919)516-2852 eanette. oowell ..raleiohnc.00v Stormwater Utility Division Main Office (919) 996-3940 From: Senior, Mark Sent: Monday, August 23, 2010 11:49 AM To: Bowden, Danny; Brown, Ben; Smith, Mac; Powell, Jeanette Cc: Hathaway, Amy; Duffy, Peter; McLawhorn, Dan Subject: Councilor Crowder request on asphalt plant and concrete plant �_I4 `228-s`l3e rG SOr—t.0^� SL,OUIcL 14q"!� "— ' 1113d--cA a.c}1Lk- rrA O' Noc-d---Lill 5 ^rc.t COCLtiS —FIG-^I Counci!pr Crowder was concerned about the asphalt plant and concrete plant near Chapel Hill Rd. (54) (attached is a photo illustrating the sites). I got responses from the State on air and groundwater but have had no response from surface water (Bradley Bennett). I told Councilor Crowder of our lack of a response and offered to look at the sites under the City's authorities. I took a quick look last week and it appears there may be grounds for enforcement under the S&E codes and possible water contamination. In the case of the asphalt plant, they have a 20-30+ foot high pile of raw material or debris (possibly from road grinding) that's visible from both Chapel Hill road and looking behind the Rising Sun Pools store off Hillsboro St. It appears this may have been contained by silt fence at one time but in looks like the base of the pile has overflowed the fence on the Chapel Hill Rd side. Not sure how much sediment they are losing as the material is fairly coarse but I'm guessing they at least need to submit for a permit if they have not done so already. The seepage from the spoil pile is also discolored. Appears to be iron bacteria at work but we should probably take a sample and have it analyzed for metals, pH, and other basic parameters. Discharge point can be accessed from Chapel Hill Rd, just up the hill from their entrance. On the concrete site, they have lots of aggregate and other raw material storage on site and some of it is pretty fine. The site backs up to a creek and it does not appear that they have much in the way of sediment control in place. Probably worth a look to see if a permit is needed and if any material is leaving the site. Will probably require hip boots as it looked like the only way to thoroughly check the back of the site was to walk up the creek. Thanks, Mark Sr. Mark T. Senior, PE, Senior Project Engineer Stormwater Services Division City of Raleigh Public Works Department PO Box 590 Raleigh NC 27602 Work Phone (919) 996-4012 Fax (919) 996-7633 Email mark.senior(a raleighnc.gov www.raleighnc.gov F; Landry, Natalie To: Powell, Jeanette Cc: mark.senior@raleighnc.gov; Hall, Mandy; Smith, Danny Subject: RE: Councilor Crowder request on asphalt plant and concrete plant Hi Jeanette, Mandy Hall and I conducted a file review and a site inspection for each of the sites mentioned below. DWQ has an NPDES Industrial Stormwater Permit for the ST Wooten Ready Mix Concrete facility, located at 5201 Beryl Road, and the Permit Number is NCG160085. DWQ inspected the site previously on 6/4/08 and the site was in compliance with the permit conditions. The Rea Contracting Asphalt Paving Mixture facility has an NPDES Industrial Stormwater Permit (No. NCG160085) and is located at 5801 E Chapel Hill Road. This site has no previous inspection records in the file. On August 26, 2010, Mandy and I conducted complaint investigations at each site. At the ST Wooten facility we observed a small, non -permitted discharge of concrete wastewater leaving the site. We discussed the problem with the plant manager and he agreed to clean up the waste and cordon off the area to traffic to prevent the washout of concrete trucks in this low area. At the Rea Contracting facility we observed groundwater seepage from the pile area and iron bacteria precipitate in the flowing water. We requested that this location be added to the routine sampling required by the NPDES permit. Comprehensive inspections for compliance with the specific NPDES Industrial Stormwater Permit will be scheduled at each site during September. The complaint issues will be followed up during the inspections and again, if necessary. If you have any questions regarding the complaint issues or permit compliance, feel free to contact me or Mandy Hall at 919-791-4200. Thank you for alerting us to these problems. Natalie Natalie Landry DENR - Surface Water Protection 3800 Barrett Drive Raleigh, NC 27609 (919) 791-4258 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Powell, Jeanette [mailto:Jeanette.Powell@raleighnc.gov] Sent: Monday, August 23, 2010 12:06 PM To: Smith, Danny Subject: FW: Councilor Crowder request on asphalt plant and concrete plant Hi Danny, A City Council member raised concerns over an asphalt plant and a concrete plant on the west side (see attached map). I am sending an inspector out to investigate, but it sounds like most of the issues raised (see below) are going to fall under the NPDES permit. Have you guys inspected or taken any enforcement action against these two sites? Thanks, j 40 Jeanette Powell, cPEsc, cPswo, cEsswl Stormwater Inspections Manager Stormwater Utility Division Public Works Department Office: (919) 516-2837 Fax: (919) 516-2852 ieanette.Dowell(a)raleiohnc.00v itormwater Utility Division Main Office (919) 996-3940 From: Senior, Mark Sent: Monday, August 23, 2010 11:49 AM To: Bowden, Danny; Brown, Ben; Smith, Mac; Powell, Jeanette Cc: Hathaway, Amy; Duffy, Peter; McLawhorn, Dan Subject: Councilor Crowder request on asphalt plant and concrete plant Councilor Crowder was concerned about the asphalt plant and concrete plant near Chapel Hill Rd. (54) (attached is a photo illustrating the sites). 1 got responses from the State on air and groundwater but have had no response from surface water (Bradley Bennett). I told Councilor Crowder of our lack of a response and offered to look at the sites under the City's authorities. I took a quick look last week and it appears there may be grounds for enforcement under the S&E codes and possible water contamination. In the case of the asphalt plant, they have a 20-30+ foot high pile of raw material or debris (possibly from road grinding) that's visible from both Chapel Hill road and looking behind the Rising Sun Pools store off Hillsboro St. It appears this may have been contained by silt fence at one time but in looks like the base of the pile has overflowed the fence on the Chapel Hill Rd side. Not sure how much sediment they are losing as the material is fairly coarse but I'm guessing they at least need to submit for a permit if they have not done so already. The seepage from the spoil pile is also discolored. Appears to be iron bacteria at work but we should probably take a sample and have it analyzed for metals, pH, and other basic parameters. Discharge point can be accessed from Chapel Hill Rd, just up the hill from their entrance. On the concrete site, they have lots of aggregate and other raw material storage on site and some of it is pretty fine. The site backs up to a creek and it does not appear that they have much in the way of sediment control in place. Probably worth a look to see if a permit is needed and if any material is leaving the site. Will probably require hip boots as it looked like the only way to thoroughly check the back of the site was to walk up the creek. Thanks, Mark Sr. Mark T. Senior, PE, Senior Project Engineer Stormwater Services Division City of Raleigh Public Works Department PO Box 590 Raleigh NC 27602 Work Phone (919) 996-4012 Fax (919) 996-7633 Email mark.senior@raleighnc.gov www.raleighnc.gov