NCG140424_NOV_20210108

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
January 8, 2021
CERTIFIED MAIL: 7018 0040 0000 4772 0189
RETURN RECEIPT REQUESTED
RC Construction Co. Inc.
Attn: Edward Murchison, QC Manager
PO Box 1998
Greenwood, MS 38935-1998
Subject: NOTICE OF VIOLATION (NOV-2021-PC-008)
NPDES Stormwater General Permit NCG140000
RC Construction Co. Inc.
IRC Construction Co./Pope Army Airfield, Certificate of Coverage NCG140424
Cumberland County
Dear Mr. Murchison:
On December 9, 2020, Penny Markle and Mike Lawyer from the Fayetteville Regional Office of the Division of Energy,
Mineral and Land Resources(DEMLR), conducted a site inspection for the RC Construction Co./Pope Army Airfield
facility located off Airborne Street, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Mr. Larry Carter and Mr. Ron Beshears with TST 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 NCG140000 under Certificate of Coverage NCG140424. Permit coverage
authorizes the discharge of stormwater and/or wastewater from the facility to receiving waters designated as Little River
(Lower Little River), class C waters in the Caper Fear River Basin.
As a result of the site inspection, the following permit conditions violation(s) are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
Per Part III of the NCG140000 permit, the permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall.include all items as indicated in the permit. During the site inspection, it was determined that the
facility's SPPP did not include the following items; Part 111, items 1(d), 5, 7, or 8.
2)Analytical Monitoring
Per Part IV, Section D of the NCG140000 permit, analytical monitoring of authorized process wastewater discharges shall
be performed as specified in Table 7 and in accordance with the schedule specified in Table 9. During the inspection, it
was determined that analytical monitoring had not been conducted and/or recorded in accordance with these permit
requirements.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Requested Response
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written
response should include a reasonable explanation as to why the aforementioned violation(s) have occurred as well as a
Plan of Action to prevent these violation(s) from recurring.
0.11 11111110k so North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
C&.-DE Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301
Q>
910.433.3300

Action Items
Immediately review and amend the facility's SPPP as necessary and begin incorporating documentation pertaining to the
annual review/update requirements of the permit. Conduct and record monitoring per the conditions of the permit.
Thank you for your attention to this matter. This office requires that the violations, as detailed above and
summarized in the enclosed inspection report, be properly resolved.These violations and any future violations
are subject to a civil penalty assessment of up to$25,000 per day for each violation. Should you have any
questions regarding these matters, please contact Mike Lawyer at(910)433-3394.
SincerelyVEQdIr
imoth
Regio
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: Larry Carter—TST
Ron Beshears—TST
Lee Ward-Directorate of Public Works, Chief Water Management Section
La Tanya Reed-DPW-Water Management Branch, Environmental Protection Specialist
Toby Vinson, Jr., PE, CPESC, CPM, Section Chief-DEMLR, Land Quality Section, Program Operations
Matt Gantt, PE, Section Chief— DEMLR, Land Quality Section, Regional Operations
Annette Lucas, PE, Supervisor— DEMLR, Land Quality Section, Stormwater Program
Alaina Morman, Environmental Specialist— DEMLR, Land Quality Section, Stormwater Program
cc: FRO—DEMLR, Stormwater Files

Compliance Inspection Report
Permit:NCG140424 Effective: 08/01/17 Expiration: 06/30/22 Owner: R C Construction Cc Inc
SOC: Effective: Expiration: Facility: RC Construction Company/Pope Army Airfield
County: Cumberland Across From Bldg 4416 Airborne St
Region: Fayetteville
Pope Army Airfield NC 28308 �
Contact Person:Edward Murchison Title: QC Manager Phone:[phone]
Directions to Facility:
At the southeast corner of Hurst Drive and Airborne St on Pope AAF
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
i
On-Site Representative(s):
On-site representative Edward Murchison 662-453-2424
Related Permits:
Inspection Date: 12/09/2020 Entry Time 03:44PM Exit Time: 05:33PM
Primary Inspector:Penny Markle" ,(A Phone: [phone]
Secondary Inspector(s):Mike Lawyer
��" -
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Ready Mix Concrete Stormwater/Wastewater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG140424 Owner-Facility:R C Construction Co Inc I-
Inspection Date: 12/09/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine facility's compliance with the conditions of the NCG140000 General Permit. Met with
Larry Carter and Ron Beshears with TST and Ed Murchison with RC Construction Company. Facility's Stormwater Pollution
Prevention Plan (SPPP)was provided for review. Several required components of the SPPP were missing, such as an
updated listing of any significant spills or notation that none have occurred, a listing of responsible parties, documentation of
an annual review and update, and a facility inspection program. Based on the facility's site map, there is a single discharge
outfall that receives stormwater flows as well as process wastewater flows that enter a settling basin prior to discharge.A
monitoring record from November 2020 indicated all discharge characteristics met the associated effluent limitations. There
were no available records indicating that monitoring had been conducted in previous quarters within the current permit term.
After the records review, site observations were made including ASTs, aggregate piles, settling basin and discharge outfall.
Page 2 of 3

Permit: NCG140424 Owner-Facility:R C Construction Co Inc
Inspection Date: 12/09/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
I
I
I
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? 0 ❑ ❑ ❑
I.
#Does the Plan include a"Narrative Description of Practices'? E ❑ ❑ ❑
#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? 0 ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑
#Does the Plan include a BMP summary? N ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? ❑ E ❑ ❑
#Is the Plan reviewed and updated annually? ❑ E ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑
Comment: There is list of spills noted for 2014 & 2017 but no current list. No documentation to support that
the SWPP is being implemented.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ 0 ❑
Comment: Facility has no storm water only discharge out-falls.
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: There was one monitorinq record for November 2020. No monitoring records for previous
quarters within the current permit cycle.
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? E ❑ ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ ❑ N ❑
Comment:
Page 3 of 3