NCG020007_CEI_20201106

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
Covia Holdings Corporation
Attn: Douglas S. Losee, VP Environmental
2829 Technology Forest Blvd, Suite 100
The Woodlands, TX 77381
NORTH CAROLINA
Environmental Quality
November 6, 2020
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG020000
Covia Holdings Corporation
Marston Plant, Certificate of Coverage NCG020007
Richmond County
Dear Mr. Losee:
On November 4, 2020, a site inspection was conducted for the Marston Plant located at 541 Cognac Road, Marston,
Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Kenneth
Akins, QC/Safety/Environmental Supervisor, Mr. Matt Wilkins, Operations Manager, and Mr. David Hayes, Plant Manager,
were also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit NCG020000 under Certificate of
Coverage NCG020007. Permit coverage authorizes the discharge of stormwater and/or wastewater, as approved in the
original permit/application or subsequent permit modification, from the facility to receiving waters designated as Clay Branch,
a class C water in the Lumber River Basin. It should be noted, however, that based on the facility's location, discharges
from certain areas of the facility located west of Cognac Road would likely be to receiving waters designated as Mill Creek
(McLeods Lake), a class C water in the Lumber River Basin.
As a result of the inspection, the facility was found to be in.compliance with the conditions of the NCG020000 permit. Please
refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or via e-mail at
[e-mail].
Sincerely,
c
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
Enclosure: Compliance Inspection Report
ec: Kenneth Akins, QC/Safety/Environmental Supervisor —Covia Holdings Corporation, Marston Plant
Matt Wilkins, Operations Manager — Covia Holdings Corporation, Marston Plant
David Hayes, Plant Manager — Covia Holdings Corporation, Marston Plant
Michelle Maxson, Environmental Specialist — Covia Holdings Corporation
cc: FRO — DEMLR, Stormwater Files
,/�_ North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
...+�" �� E Q> Fayetteville Regional Office ) 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
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Compliance Inspection Report
Permit: NCG020007 Effective: 10/01/20 Expiration: 05/01/21 Owner: Covia Holdings Corporation
SOC: Effective: Expiration: Facility: Marston Plant
County: Richmond 541 Cognac Rd
Region: Fayetteville
Marston NC 28363
Contact Person: Michele Maxson Title: Environmental Specialist Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Kenneth Akins 910-582-4816
On -site representative David Hayes 910-582-4816
On -site representative Matt Wilkins 910-582-4816
Related Permits:
Inspection Date: 11/04/2020 Entry Time 09:55AM Exit Time: 12:40PM
Primary Inspector: Mike Lawyer Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Mining Activities Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG020007 Owner - Facility: Covia Holdings Corporation
Inspection Date: 11/04/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection for compliance with the conditions of the NCG020000 permit conducted in conjunction with an inspection for
compliance with the facility's mining permit (77-06). Observations were made of the mine site including the
settling/recirculating ponds, excavation areas, waste sand disposal areas and ASTs with appropriate secondary
containment. Reviewed the facility's Stormwater Pollution Prevention Plan (SPPP) and available monitoring records since the
previous inspection conducted on August 28, 2018. The SPPP appears to contain all required components as well as
documentation associated with the annual review and update requirements. Monitoring records indicate a wastewater
discharge monitoring event in September of 2018, no discharges in 2019, and a wastewater discharge monitoring event in
February of 2020. Both of the wastewater discharge monitoring events resulted from the facility pumping water out of one of
their settling/recirculating ponds in preparation for Hurricane Florence (2018) and in response to high water levels due to
intense storm event (2020). There were also unanticipated bypasses/discharge events in September 2018 and February
2020, which were appropriately reported and addressed.
Page 2 of 3

Permit: NCG020007 Owner - Facility: Covia Holdings Corporation
Inspection Date: 11/04/2020 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?
E
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑
❑ E ❑
# Does the facility provide all necessary secondary containment?
0
❑ ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
E
❑ ❑ ❑
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ 0 ❑
Comment: Facility has no distinct stormwater discharge outfalls.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ 0 ❑
Comment:
Page 3 of 3