NCG140095_COMPLETE FILE - HISTORICAL_20120928

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/v
DOC TYPE,
HISTORICAL FILE
11 MONITORING REPORTS
DOC DATE
o o I
YYYYMMDD

H M M,
1C O N CR`E•TEc: fCP0XPANY'
THOMAs E. CHANDLER, JR.
PRESIDENT
September 28, 2012
Danny Smith
Regional Supervisor — Water Quality
NC DENR
1628 Mail Service Center
Raleigh, NC 27699
Dear Mr. Smith,
VIA CERTIFIED MAIL
By means of this letter I certify that Kenneth E. Waegerle, Environmental, Health & Safety
Manager, is the duly authorized representative for Chandler Concrete Company, Inc., and for
Chandler Concrete/Piedmont, Inc. He is responsible for the overall environmental operations
and has the authority to sign documents and to shut down the operations should an emergency
occur for an}, of our plants in North Carolina. The plants in the Raleigh Region include, but not
limited to the following locations:
Plant
Siler City
Pittsboro
Hillsborough
Durham Pettigrew St.
Durham Ellis Rd.
Roxboro
Thank you for your attention to this matter.
Sincerely,
i
1'. E. Chandler, Jr.
President
County
Num.
Chatham
109
Chatham
III
Orange
602
Durham
603
Durham
606
Person
607
POST OFFICE Box 131 • BURLINGTON, NORTH CAROLINA 27216-0131
TELEPHONE: [phone] / FAx: [phone]

Chandler
THOMAs E. CHANDLER, JR.
PRESIDENT
September 28, 2012
Danny Smith
Regional Supervisor — Water Quality
NC DENR
1628 Mail Service Center
Raleigh, NC 27699
Dear Mr. Smith,
VIA CERTIFIED MAIL
By means of this letter I certify that Kenneth E. Waegerle, Environmental, Health & Safety
Manager, is the duly authorized representative for Chandler Concrete Company, Inc., and for
Chandler Concrete/Piedmont, Inc. He is responsible for the overall environmental operations
and has the authority to sign documents and to shut down the operations should an emergency
occur for any of our plants in North Carolina. The plants in the Raleigh Region include, but not
limited to the following locations:
Plant
Siler City
Pittsboro
CDucham-PEftigrew--S
Durham Ellis Rd.
Roxboro
Thank you for your attention to this matter.
Sincerely,
T. E. Chandler, Jr.
President
Countv
Num.
Chatham
109
Chatham
III
Durham
603
Durham
606
Person
607
1, If
2W L
jL
POST OFFICE BOX -131 • BURLINGTON, NORTH CAROLINA 27216-0131
TELEPHONE: [phone] / FAX: [phone]

Permit: NCG140095
SOC:
County: Durham
Region: Raleigh
Compliance Inspection Report
Effective: 08/01/04 Expiration: 07/31/09 Owner: Chandler Concrete Co Inc
Effective: Expiration: Facility: Chandler Concrete Co-Plt#603
2700 E Pettigrew St
Contact Person: James J Woody
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Inspection Date: 07/31/2008 Entry Time: 02:30 PM
Primary Inspector: Mack K Wiggins
Secondary Inspector(s):
Durham NC 27713
Phone: [phone]
Certification:
Exit Time: 04:30 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: Ready Mix Concrete Stormwater/Wastewater Discharge
COC
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page:1

Permit: NCG140095 Owner - Facility: Chandler Concrete Co Inc
Inspection Date: 07/31/2008 Inspection Type: Stonnwater
Inspection Summary:
Reason for Visit: Routine
Page:2

Permit: NCG140095 Owner - Facility: Chandler Concrete Co Inc
Inspection Date: 07/31/2008 Inspection Type: Stormwater
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
n
n
n
n
# Does the Plan include a General Location (LISGS) map?
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
n
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
n
❑
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
n
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
n
n
n
# Does the facility provide all necessary secondary containment?
n
n
n
n
# Does the Plan include a BMP summary?
n
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
n
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
n
n
n
n
# Does the facility provide and document Employee Training?
n
n
n
n
# Does the Plan include a list of Responsible Party(s)?
n
n
n
n
# Is the Plan reviewed and updated annually?
n
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
n
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
n
n
n
n
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
n
n
n
n
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
n
n
n
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
n
n
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
n
n
n
n
# Were all outfalls observed during the inspection?
n
n
n
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
n
n
# Has the facility evaluated all illicit (non stormwater) discharges?
n
n
n
n
Comment:
Page:3

Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
--I
z, Y
November 9, 2006
Mr. James Woody -
Safety/Environmental Manager
Chandler Concrete Co.
1006 S. Church St.
Burlington, NC 27216-0131
Subject: Compliance Evaluation Inspection
Chandler Ready Mixed Plant in Durham, NC
Stormwater Permit No. NCG140095
Durham County
Dear Mr. Woody:
Alan W. Klimek, P.E., Director
Division of Water Quality
At your invitation, Mack Wiggins and Myrl Nisely from the Raleigh Regional Office of
the Division of Water Quality conducted a site visit on October 31, 2006 to note changes
made in the plant in recent months. They took the opportunity to complete a compliance
evaluation. The site tour provided by Bruce Oakley, Jon Faubel and you was greatly
appreciated. This plant is now in compliance as a result of significant changes made by the
company as Phase I. A Phase II is planned when budgets will allow.
On the southeast side of the facility regrading and paving now directs all stormwater and
wastewater into a set of 5 cells. Wastewater no longer makes its way to drains in the street.
The cells provide settling of solids, and in the last cell the water is pH adjusted with CO2
and stored in a large tank for reuse. The large area at the top of the hill where broken
waste concrete used to be has been reduced in size and moved to the side. In its place, two
truck washoff stations now provide opportunity for drivers to use either fresh water or the
treated recycle water. Reuse water is also used in the truck tanks for washing chutes at
customers' locations.
The plant has implemented an impressive set of reminders to help workers perform regular
maintenance activities. The pH probe is calibrated weekly and cannot be avoided because
the computer triggers a check. Grates are emptied weekly. The plant now owns a large
sweeper, used on the concrete parts of the driveway every other day. A set schedule also
assures solids removal from the various cells.
A grate across the SE entrance has been altered to drain to the isolated cell nearest the
street. This cell can potentially overflow to the storm drain discharge manhole described
below, but pH can be altered before any release by using already treated water from the
storage tank or by adding acid as needed. Caution: this manual adjustment process needs
to anticipate heavy rain events and is still a potential point for release of wastewater not
meeting permit limits.
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone]
Internet: www.ncwateraualily.or¢ 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
Customer Service 1-877-623-6749

Chandler Durham CEI 10/31 /2006 Page 2 of 2
A similar drain at the other entrance collects runoff for settling. Overflows travel to a
stormwater discharge manhole a few feet to the north, the single point of discharge from
the site. This manhole also receives flow from aggregate piles and from the NW loading
station, so is considered to be a discharge of wastewater, rather than stormwater. Careful
attenuation of solids and pH must be achieved at this station to meet permit limits. The
parameters include settleable solids because aggregate runoff is included. Sampling, after
removing the grate, is done by collecting water dropping in from the surrounding area. The
collection is made above other rainwater running through this manhole a few feet lower.
That stormwater has been collected by other systems off site. For safety, a two -man team
should do this sampling operation.
A couple of small changes were discussed and agreed to during the inspection. A drum of
release agent resting on a slab where blocks are poured from left -over concrete should have
secondary containment around it. Along the back side of that slab, better spill control can
be realized by placing blocks against the edge of the slab and then sealing the joint to keep
liquid from escaping. With this improvement, any spill would travel to the recycle cell
system further down the hill instead along the edge of the property.
Should you have any questions regarding this visit, please contact me at 919-791-4255.
Sincerely,
I 'i
MYyrA 21yL'J
Environmental Chemist
Mack Wiggin��
Environmental Technician
cc: Danny Smith — NPS Assistance and Compliance Oversight
Bethany Georgoulias — Stormwater Permitting Unit
Central Files
cRRO/SWP File
w
rna �
IlJls��

Questions for General Permit Inspections
Date: 10/31/2006 Permit No. NCG140095 Facility: Chandler Concrete
Time In: 09:35 Departure Time: 11:35 Inspector(s): Myrl Nisely and Mack Wiggins
YES
NO
NA
NE
1.
Is a copy of the Permit and the Certificate of Coverage available at the site?
®
❑
❑
❑
2.
Does the Plan include a General Location (USGS) map?
❑
®
❑
❑
3.
Does the Plan include a "Narrative Description of Practices"?
®
❑
❑
❑
4.
Does the Plan include a detailed site map including outfall locations?
❑
®
❑
❑
5.
Does the Plan include a list of significant spills in the past 3 years?
❑
®
❑
❑
6.
Has the facility evaluated all illicit (non stormwater) discharges to the storm sewer system?
®
❑
❑
❑
7.
Has the facility evaluated feasible alternatives to current practices?
®
❑
❑
❑
8.
Does the facility provide all necessary secondary containment?
®
❑
❑
❑
9.
Does the Plan include a BMP summary?
®
❑
❑
❑
10.
Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®
❑
❑
❑
11.
Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
®
❑
❑
❑
12.
Does the facility provide and document Employee Training?
®
❑
❑
❑
13.
Does the Plan include a list of Responsible Party(s)?
®
❑
❑
❑
14.
Is the Plan reviewed and/or updated annually?
®
❑
❑
❑
15.
Does the Plan include a Stormwater Facility Inspection Program?
®
❑
❑
❑
16.
Has the Plan been implemented?
®
❑
❑
❑
17.
Has the facility conducted its Qualitative Monitoring semi-annually?
®
❑
❑
❑
18.
Has the facility conducted its Quantitative (Analytical) monitoring?
®
❑
❑
❑
19.
Does the facility have Vehicle Maintenance activities on site (uses more than
55 gallons of new motor oil per month)?
❑
®
❑
❑
19a. Has the facility conducted its Annual Quantitative (Analytical) monitoring at outfalls
receiving runoff from Vehicle Maintenance areas?
❑
❑
®
❑
20. Were all outfalls observed during the inspection?
®
❑
❑
❑
21. If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
®
❑
Comments: The site tour provided by Bruce Oakley, Jon Faubel and you was greatly appreciated. This plant is
now in compliance as a result of significant changes made by the company as Phase I. A Phase 11 is planned when
budgets will allow. All water discharging from this site is to be considered process wastewater.
Recommendations:

Requirements: Place a USGS map containing the details stated in the permit into the manual. The plan must
include the past three years of significant spills, so an update to include 2005 spills need to be added. If none, so
state.
The slab in the area for pouring blocks with left over concrete has a drum of release agent that should have a
secondary containment around it. Along the back side of that slab, better spill control can be realized by placing
blocks against the edge of the slab and then sealing thejoint to keep liquid from escaping. With this improvement,
any spill would travel to the recycle cell system further down the hill.
Take care to assure samples of the discharge are representative and meeting permit limits. Your sample point will
be given close attention at the next site visit.

I � �
CONCRETE COMPANY
HCGINoOgs
November 21, 2006
Mr. Myrl A. Nisely, Environmental Chemist
NC DENR
Division of Water Quality
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Mr. Nisely:
I just wanted to express my appreciation to you and Mack Wiggins for your time,
comments, and suggestions during your visit to our Durham Plant 4603. The input from
your visits to this site has been very positive and helpful. It has been and continues to be
the goal of our company to be environmentally friendly and to set the standards for our
industry. As I have stated before that this mission takes time and in most cases big
dollars.
I have revised the site and location maps and included them in the SWPPP along
with a current list of significant spills. We have also added the straw bales along the
discharge stream from plant # 2. The depression directly behind the truck loading point
of plant # 1 will be filled in and leveled so that this area can be cleaned and not create
additional sediment from flowing to the settling pit near the street in the next few weeks.
I realize that this sediment pit continues to be a potential problem area, and will continue
to try to make improvements in order alleviate this problem.
Again, I appreciate your suggestions and concerns as well as you and Mack taking
time to help us.
Sincerely,
ames J. Woody
Environmental Manager
NOU 9 ? 2006
U R RALIIGr REGIMAL OFFICE
POST OFFICE Box 131 • BURLINGTON, NORTH CAROLINA 27216-0131
TELEPHONE: [phone] / FAx: [phone]

Chandler
December 30, 2002—
iti
--- _
Mr. Kenneth Schuster 1
Regional Supervisor ijf JAN 2 - 2003
Division of Water Quality
NCDENR — -`
'u
1628 Mail Service Center 4 ..........
Raleigh, NC 27699-1628
RE: Notice of Violation CERTIFIED MAIL
Permit No. NCG 140095
Durham, NC
Durham County
Dear Mr. Schuster:
This is in response to your letter dated November 25, 2002. By means of this letter I will respond to
reasons why there should be no enforcement taken against Chandler Concrete. This will be covered
in my responses to your list of violations.
History: This plant was constructed prior to there being any storm water permits or for that fact
concerns about water discharges. Since this was the scenario no thought was give as to the location
of the plant and buildings with reference to capturing all discharge water.. As a result everything is
in the wrong location in order to be in compliance with the storm water permit. To be in compliance
major, major work would have to be performed to relocate structures in order to be able to capture all
process/storm water so as to treat properly prior to discharge. There have been several costly
improvements made in the last three or four years.
As to your list of violations these are the responses.
a) In my interruption of the storm water permit that discharge from the stockpiles do not
have to be captured and can be discharged provided it meets the permit parameters. This
is clear water that originates from the city of Durham water supply.
b) As I have stated to you on previous occasions we have not come up with a economically
feasible solution to reduce the pH. We are actively investigating ways to control the pH
of this water. We do recycle some of this water which has greatly reduced the amount
that could be discharged. We would appreciate any suggestions that you may have on the
reduction of the pH of this water.
POST OFFICE BOX 131 • BURLINGTON, NORTH CAROLINA 27216-0131
TELEPHONE: 336 • 226 • 1181 / FAx: 336 • 570 • 0557

c) All of our employees receive annual training on all environmental issues. This occurs at
each plant location and during our annual company wide training sessions held here in
Burlington. Copies of that documentation will be added to the SW3P.
d) There is a statement in the SW3P handbook on page 2 under Site Assessment that there
have been no significant spills or leaks at this location in the past three years. This book
was just revised this year. If a significant spill or leak occurs our people have been
instructed to notify the proper authorities, make a notation of any such occurrence and
place it in the SW3P book.
e) Semi-annual inspections are required for all of our locations. Copies of these inspections
have been kept at our corporate office. I was not aware that they needed to be on file at the
individual locations. Copies are being forwarded to this plant location to be filed in the
SW3P.
f) Annual sampling data has been submitted to the State as per requirements. A copy has
been kept at the corporate office. Copies of these data are being sent to the plant site.
g) This item has been added to the BMP for this location.
h) This is a very harsh negative statement. I disagree with you, there is evidence that much
work has been done to comply with the permit requirements of implementing the plan.
There has been training, inspections, sampling, proper preventative maintenance on the
vehicles and plant, as well as implementing BMPs.
In response to your statement about a NOV dated November 29, 2001, I am not aware of such a
letter. The secondary containment is one of the many items that has been done at this and other
locations in order to control any potential spills.
I appreciate your recommendations. I will admit that more detail can always be added. Our
philosophy is to always strive to meet or exceed permit requirements. We believe in keeping it
simple, and covering the major issues and concerns. Several of your recommendations are not
addressed in the actual permit. There is no mention as to the order of listing in the guidelines from the
EPA. It is of our contention that all of the major items of the permit are covered. As I related to you
in our meetings that there has to be some consideration as to the cost of compliance to these permits.
We have been and still are actively investigating all proven methods for treatment of these waters.
Chandler Concrete has already spent considerable dollars and made many improves this site over the
past few years in order to be in compliance with the permit. By construction of settling ponds, berms,
catch basins, piping and reusing the water we have reduced the discharge from this plant
considerably. By the construction of the liquid admixture containment we have all but eliminated the
possibility of any contaminated discharge.
You stated that the industry has had ample time to bring these sites in compliance. I respond that the
conditions under the original permit were changed drastically upon the renewal. Our company and
industry has been working through the state and national associations to be in compliance with the
storm water permitting. At the present time there is no economically feasible method to meet the
discharge regulations. We will continue to strive to meet all permit requirements.

t�
.r a ..t. .. I . r • I
.:JI ..lf' i1� r•.�• .r. .I :i<:sir !l '.. .t ..
. ...r .r. ..• 1 .. .'!!1 '.... _ . a a 1A I 14, r. ... .. W. '1" .. - 1 L,
.:i ..I. .). 7.r. r:r rJ,1 �.t.':'" _ rf. .. .r. .. iJ 1',�:1•i)"fa�;.. J'<< ._.. is
r 1
•. .Ia. l.: fu..r t •I.a 'S' .�!: .:! ... ... ar. �5: r. rt, r _.I, .. �rli ... .•. , •. r jqT
Ii _r [.. .. !. r.. a .!�.r'1 1; .. ,� ..t: :r l: r.!�1. ..1 •. +i '' .. .. . '`7,' . I. . •Y . •�: ({�.
r r r 1
.:i S:.r:`+2^. .. .ia ju(1, ,. 1•r .. ='oi A?ter 1'•11:1.'1:";i' .[' li!(,r, a 4':. Jf•(..;('.!.7.:.r.
ia'(I: 1:. 1. it r. '•. �: !! r. •. .. r �'. I:. .,.. •l.f .7 ..J `.'�!'?. '7 .•.
.. 9: .. • .. :r. r .. •. .i ... I:i'. (:. r. .. .., v1:. "r!'1. .'t. 't.> . t.. i` _ 'G ::4' • ., �J
.'"1'. ...,. .! . r ..,r .. I°•,u r. .. .'rrq .�'i: ., .. .i: ..•,.1 .. .i'�yn 1, P:r ��, d:G
.-ly '�'�:[":''. i'.'.i.� ': :: '.V !.t' J.: (r l':'fi.:.... r. .'Iri':!.:. r' .r. � .,••I.!li.' .• !L.):^::I: 't!l
. ..(; ti„'�r':•i.r ;J41 ;'r'r .. .''i 'J'.i; .,t Vp 'ii ..:i .. lqw. .. Aa :'r:'... i'}t"�' .'Y•ji '.... �.d �. :i:r•:r.

Since there appears to be no violations of the General Storm Water Permit at this location I request
that the NOV be rescinded. If not then I request the right to appeal.
Sincerely, / '
G4/
ames J. oody
Safety/Environmental Manager

State of North Carolina
Department of Environment ,�'/�
and Natural Resources
Raleigh Regional Office ���
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE50URCE5
Division of Water Quality
November 15, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. James Woody
Chandler Concrete Co - PLT. 603
P.O. Box 131
Burlington, NC 27216
Subject: Notice of Violation
Failure to Implement Stormwater Permit
Permit No. NCG 140095
Durham, NC
Durham County
Dear Mr. Woody:
On September 24, 2002 Mr. Myrl Nisely of the Raleigh Regional office of Division of Water
Quality made a compliance inspection of Chandler Concrete Plant 603 in Durham. The help of
Danny Brame was appreciated.
History: A general stormwater permit for ready mix concrete production facilities was first
issued in 1994. The permit was revised effective August 1, 1999, and that version gave all
permit holders 24 months, until August 31, 2001 to fully establish the elements required by the
permit.
Documentation is in two three-ring binders, one labeled Stormwater SPPP and the other
Environmental Handbook. The SPPP manual was issued in May, 2002. Together these provide
the basic planning and forms to use, but there was little data to show execution and active
compliance. Under the five year records retention requirement, there should have been records in
the manual of an implemented stormwater program from about 1997 to the present. In light of
the considerable time that the permit has existed, this office is recommending that an
enforcement action be taken against Chandler Concrete for failure to fulfill permit requirements.
Please provide in your written response any reasons as to why enforcement should not be taken
against Chandler Concrete.

Chandler Concrete, October 1, 2002 p. 2
Mr. Woody's responses in italics (shortened). My counter responses in bold.
The following violations of Durham Permit No. NCG140095 were observed:
I failed to mention the need for a site map. Partll(A)(1)(c)
a) At this site water runs toward collection points from the back of the plant toward the
street. Most enter storm drains on the site, but a wet flow from a sand storage pile made
its way to the street storm drain. The path of this flow was green with algae. This release
must be captured. Can be discharged if meets permit. Clear Durham city water Can you
provide data from sampling that water to assure it meets the parameter limits? No
such data was on -site the day of inspection.
b) A routine release occurring from the newest cell, called the Dust Pond by Mr. Brame, to
the storm drain had a pH of 11.55. This is a direct violation of the 6 to 9 pH limit.
Likewise, the contents of the long grate at the southern entrance showed pH 11.3.
No economical way. Open to suggestions. Recycle much of it Until a fix, this is a violation. A
local company is working on a system of pH adjustment and solids reduction that may be
something that can be shared.
c) Employee training in May, 2002 appeared to have been provided only to top managers,
not to all employees. As you explained in our meeting on 9/27/02, all employees actually
do receive considerable training. Documentation of that needs to be in the SPPP binder.
Corporate training is given to all. Will add to book
d) There was no list of significant spills, or a signed page specific to this location stating that
there had been none. Significant spills are defined as at or above the reportable quantity
for that substance, but any spill large enough to be cleaned up should be called in to the
Regional office and be recorded on the SPPP spill page.
Statement p2 under Site Assessment. Employees instructed what to do OK, but consolidated
book would have helped locate this info. Separate spill report from Employee training and
have both in the right parts of the manual.
e) No semi-annual site inspections were available. Mr. Brame stated that in heavy rains the
greatest runoff occurs close to the office building. Please document the fate of that flow
by direct employee observation during a rain.
Semiannual insp records in corporate office. Will go to SP3 So this was (will be)OK
f) There was no evidence of annual sampling or certification that none was needed because
of no discharge (Section B).
Records in Corp office, submitted to State. Will go to SP3 On each inspection we will review
to see proper sampling, reporting, and that analytical data is stored in SP3.
g) There was a thick buildup of fine dust over much of the site, especially beside the "Dust
Pond" where heavy rain would wash some of it toward the grate at the middle entrance,
and not to the Dust Pond. The SPPP should include a BMP for dealing with this issue.
Added to BMPs for this location.
h) In summary, that has been almost no implementation of the plan per Section A9.
Harsh negative statement, disagree. More had been done than what an inspector could see in
the SP3. Still, high pH water was being released from the site. SP3 will reflect effort in
future. Harshness was based upon what was available to the inspector.
On the plus side, the requirement in a letter of NOV dated November 29, 2001 to install
secondary containment for admixture chemicals has been accomplished..
Not aware of this letter. Apparently I confused letters sent to Siler City and Pittsboro.
In a meeting at the Raleigh Regional office on September 28 with Myrl Nisely and me, the
following improvements in the Chandler program were recommended:
1628 Mail Service Center, Raleigh, NC 27699-1628 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer pape

Chandler Concrete, October 1, 2002 p. 3
• Consolidate the stormwater materials presently in the two binders into the site -specific SPPP
binder
• Organize the program elements in the same order they are listed in the permit. Tabs labeling
the parts will be helpful to users and inspectors
• For Part II Section A 1.(a), Prepare a USGS-type map "zoomed" in or out as necessary to
show the facility's location in reference to transportation routes and the route of all
stormwater discharges all the way to the receiving water(s). Clearly identify the name of
receiving stream(s).
• The narrative required in (b) should be detailed for each plant, in addition to the present
general description of manufacturing processes.
• Give considerable detail on the site map as requested in (c), including designations of the
area served by each discharge, even if the flow away from the site is sheet flow.
• Section A2. calls for a narrative of just what practices will be used to control stormwater.
Considerable detail is given in this section of the permit. In particular, more detail is needed
for the BMPs for each drain site.
• Discharges to waters of the State must meet the 6 to 9 pH specified in the permit. You
indicated that a means of lowering pH was being considered. Please provide details on how
that would be accomplished.
• Documentation of Section A4, Preventative Maintenance and Good Housekeeping should be
in the manual, covering the details described in that part of the p rmit.
• As mentioned above, Section A5 employee training must be the PPP manual.
• A6 Responsible Party should actually state a name, in addition to job title as is now done.
• A means of showing that an update of the SPPP was accomplished at least annually should
be provided (and more often, if major changes are made at the plant).
Appreciate these, know that more detail can always be added. Our philosophy is to ...keep it
simple and cover the major issues and concerns. Several of your recommendations are not
addressed in the actual permit. (ex. order of listing) All major items have been covered,
considerable dollars have been spent ... we have all but eliminated the possibility of any
contaminated discharge. In the big picture much has been done. But following only the
major items (decided by Chandler Concrete) and omitting "minor" details of the permit is
still short of permit compliance.
...conditions under the original permit were changed drastically upon the renewal. Technical
Bulletin issued August, 1999 acknowledged major changes, then granted 24 months from
date of permit issue for companies to phase them in. Obviously, the State and EPA
expected this would be accomplished. At this time there is no economically feasible method to
meet the discharge regulations. Was this concluded from studies done since our September
meeting? I am aware of a company in this area actively working on a system that appears
to be modestly priced. If not made proprietary, permission will be sought for distributing
the design.
Please respond in writing to Mr. Myrl Nisely of this office by December 31, 2002 to provide the
feedback requested above and a general progress report.
Sincerely,
Kenneth Schuster, P.E.
Regional Supervisor
cc: NPDES Compliance Unit etc.
1628 Mail Service Center, Raleigh, NC 27699-1628 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer pape

State of North Carolina
Department of Environment 1LF.0•'_W
and Natural Resources
Raleigh Regional Office ��
Michael F. Easley, Governor NCDENR
NORTHOF
William G. Ross, Jr., SecretaryDEPARTMENT ENVIRONMENT
AND N NATURAL RESOURCES
Division of Water Quality
November 15, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. James Woody
Chandler Concrete Co - PLT. 603
P.O. Box 131
Burlington, NC 27216
Subject: Notice of Violation
Failure to Implement Stormwater Permit
Permit No. NCG 140095
Durham, NC
Durham County
Dear Mr. Woody:
On September 24, 2002 Mr. Myrl Nisely of the Raleigh Regional office of Division of Water
Quality made a compliance inspection of Chandler Concrete Plant 603 in Durham. The help of
Danny Brame was appreciated.
History: A general stormwater permit for ready mix concrete production facilities was first
issued in 1994. The permit was revised effective August 1, 1999, and that version gave all
permit holders 24 months, until August 31, 2001 to fully establish the elements required by the
permit.
Documentation is in two three-ring binders, one labeled Stormwater SPPP and the other
Environmental Handbook. The SPPP manual was issued in May, 2002. Together these provide
the basic planning and forms to use, but there was little data to show execution and active
compliance. Under the five year records retention requirement, there should have been records in
the manual of an implemented stormwater program from about 1997 to the present. In light of
the considerable time that the permit has existed, this office is recommending that an
enforcement action be taken against Chandler Concrete for failure to fulfill permit requirements.
Please provide in your written response any reasons as to why enforcement should not be taken
against Chandler Concrete.

Chandler Concrete, October 1, 2002 p. 2
The following violations of Durham Permit No. NCG140095 were observed:
a) At this site water runs toward collection points from the back of the plant toward the
street. Most enter storm drains on the site, but a wet flow from a sand storage pile made
its way to the street storm drain. The path of this flow was green with algae. This release
must be captured.
b) A routine release occurring from the newest cell, called the Dust Pond by Mr. Brame, to
the storm drain had a pH of 11.55. This is a direct violation of the 6 to 9 pH limit.
Likewise, the contents of the long grate at the southern entrance showed pH 11.3.
c) Employee training in May, 2002 appeared to have been provided only to top managers,
not to all employees. As you explained in our meeting on 9/27/02, all employees actually
do receive considerable training. Documentation of that needs to be in the SPPP binder.
d) There was no list of significant spills, or a signed page specific to this location stating that
there had been none. Significant spills are defined as at or above the reportable quantity
for that substance, but any spill large enough to be cleaned up should be called in to the
Regional office and be recorded on the SPPP spill page.
e) No semi-annual site inspections were available. Mr. Brame stated that in heavy rains the
greatest runoff occurs close to the office building. Please document the fate of that flow
by direct employee observation during a rain.
f) There was no evidence of annual sampling or certification that none was needed because
of no discharge (Section B).
g) There was a thick buildup of fine dust over much of the site, especially beside the "Dust
Pond" where heavy rain would wash some of it toward the grate at the middle entrance,
and not to the Dust Pond. The SPPP should include a BMP for dealing with this issue.
h) In summary, that has been almost no implementation of the plan per Section A9.
On the plus side, the requirement in a letter of NOV dated November 29, 2001 to install
secondary containment for admixture chemicals has been accomplished.
In a meeting at the Raleigh Regional office on September 28 with Myrl Nisely and me, the
following improvements in the Chandler program were recommended:
• Consolidate the stormwater materials presently in the two binders into the site -specific SPPP
binder
• Organize the program elements in the same order they are listed in the permit. Tabs labeling
the parts will be helpful to users and inspectors
• For Part II Section A L(a), Prepare a USGS-type map "zoomed" in or out as necessary to
show the facility's location in reference to transportation routes and the route of all
stormwater discharges all the way to the receiving water(s). Clearly identify the name of
receiving stream(s).
• The narrative required in (b) should be detailed for each plant, in addition to the present
general description of manufacturing processes.
• Give considerable detail on the site map as requested in (c), including designations of the
area served by each discharge, even if the flow away from the site is sheet flow.
• Section A2. calls for a narrative of just what practices will be used to control stormwater.
Considerable detail is given in this section of the permit. In particular, more detail is needed
for the BMPs for each drain site.
1628 Mail Service Center, Raleigh, NC 27699-1628 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer pape

Chandler Concrete, October 1, 2002
p. 3
• Discharges to waters of the State must meet the 6 to 9 pH specified in the permit. You
indicated that a means of lowering pH was being considered. Please provide details on how
that would be accomplished.
• Documentation of Section A4, Preventative Maintenance and Good Housekeeping should be
in the manual, covering the details described in that part of the permit.
• As mentioned above, Section A5 employee training must be the SPPP manual.
• A6 Responsible Party should actually state a name, in addition to job title as is now done.
• A means of showing that an update of the SPPP was accomplished at least annually should
be provided (and more often, if major changes are made at the plant).
Please respond in writing to Mr. Myrl Nisely of this office by December 31, 2002 to provide the
feedback requested above and a general progress report.
Sincerely,
Kenneth Schuster, P.E.
Regional Supervisor
cc: NPDES Compliance Unit
Durham Co. Health Dept.
Central Files
1628 Mail Service Center, Raleigh, NC 27699-1628 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer pape

1,
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
JAMES WOODY
CHANDLER CONCRETE CO - PLT. 603
P. O. BOX 131
BURLINGTON, NC 27216
Dear Permittee:
MAI
1\ �:
r
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 26, 1999
- - Subject: Reissue - NPDES Stormwater Permit -
Chandler Concrete Co - Pit. 603
COC Number NCG140095
Durham County
In response to your renewal application for continued coverage under general permit NCG 140000, 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 NCG140000
* 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 [phone], ext. 584
Sincerely,
for Kerr T. Stevens
cc: Central Files
S' -mwater and General permits Unit Files -- - -
—Raleigh Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10 % post -consumer paper

I.,
STATE OF NORTH. CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG140000
CERTIFICATE OF COVERAGE No. NCG140095
STORMWATER AND PROCESS WASTEWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
CHANDLER CONCRETE CO - PLT. 603
is hereby authorized to operate a process wastewater treatment system, and is hereby authorized to discharge process
wastewater and stormwater from a facility located at
CHANDLER CONCRETE CO - PLT. 603
2700 EAST PETTIGREW ST
DURHAM
DURHAM COUNTY
to receiving waters designated as a UT of Little Lick Creek 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. NCG140000 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 26, 1999.
for Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

State of North Carol
Department of IP
Health and `tJr�a~'
Division � nv nm
Ja L�r 1R,
Jona B. ow� s�
A. PrOW rd P H` J
James Wooer}
Chandler Concrete Co
P. O. Drawer 1239
Burlington, NC 27216
Dear James Woody
nt,
rces
'Management
P.E., Director
February 24, 1995
Subject: General Permit No. NCG 140000
Chandler Concrete Co
COC NCG 140095
Durham County
In accordance with your application for a stormwater discharge permit received on November 29, 1994, we.
are forwarding herewith 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.
The stormwater permit you are receiving, NCG140000, does not permit wasting concrete, dumping excess
concrete, directly into storm sewer outfalls or into waters of the state. Any facility which either dumps excess
concrete or washes excess concrete into storm sewers or waters of the state will be operating in direct violation to
both the terms of this permit and the North Carolina General Statutes. Such a discharge shall be considered an
illegal discharge and may subject the owner to enforcement actions in accordance with North Carolina General
Statutes 143-215.6A
If any parts, measurement frequencies or sampling requirements contained in this permit 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 in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings Post Office Drawer 27447,
Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final and binding.
Please take notice that this certificate of coverage is not transferable. Part fl, B.2. addresses the
requirements to be followed in case of change in ownership or control of this discharge.
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. ANTONI0 EVANS at telephone
number 919/733-5083, extension 584.
pri fiat Si,ned
Sincerely. coleen L1. Sullins
A. Preston Howard, Jr. P.E.
cc: - Raleigh Regional Office
Mr. Roosevelt Childress, EPA
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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. NCG140000
CERTIFICATE OF COVERAGE No. NCG140095
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,
Chandler Concrete Co., Inc.
is hereby authorized to discharge stormwater from a facility located at
Chandler Concrete Co., Inc.
2700 East Pettigrew Street
Durham, NC
Durham County
to receiving waters designated as an unnamed tributary to Little Lick Creek in the Neuse River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111
and IV of General Permit No. NCG140000 as attached.
This certificate of coverage shall become effective February 24, 1995.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day February 24, 1995.
Original
:;olnen H.
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission