NCG140424_NOV Response_20210120

RCcoNSTRUCTION CO. INC.
[phone] PHONE
18 January 21
North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
ATTN: Timothy L. LaBounty, PE
P.O. BOX 1998
818 WALNUT STREET
GREENWOOD, MS 38935-1998
[phone] FAX
RECEIVED
q3Pry-)
JAN 1.0 2021
DEMLR
i-ayetteville Regional Office
RE: Notice of Violation (NOV-2.021-PC-008)
NPDES Stormwater General Permit NCG140000
RC Construction Co. Inc.
RC Construction Co./Pope Army Airfield, Certificate of Coverage
NCG140424
Cumberland County
Mr. LaBounty:
In response to the Notice of Violation (NOV-2021-PC-008) for the Certificate
of Coverage NCG140424, I offer the following:
RC Construction acknowledges the deficiencies in compliance with the NPDES
General Permit requirements. Corrective action for the specific issues noted
in the Notice of Violation are listed below:
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 III, items l(d), 5, 7, and 8.
a. Part III item 1(d) - A list of significant spills or leaks of
pollutants during the previous three (3) years and any corrective
actions taken to mitigate spill impacts.
Response: Located in the Batch Plant SWPPP binder is a tabbed section
noted as "Incidents." One spill was noted in the section. It occurred
on Friday, 27 Mar 20. The batch plant purged two 5000-gallon potable
water tanks used for conditioning the water during Shark II concrete
placements. The daily journal entry was attached to the images taken
during the "spill." This was shown to the inspector; however, as it
was not in the format/order he expected and was discounted. Too, the
"Significant Spill" page did not reflect this event. This oversight
has been corrected and an up-to-date "Significant Spills" tab is
within the pages of the SWPPP binder.
b. Part III item 5 - Facility Inspections. Inspections of the facility
and all stormwater systems shall occur as part of the Preventative
Maintenance and Good Housekeeping Program at a minimum on a semi -
randy owned and operated since 4987 www.reeonst.net

annual schedule, once during the first half of the year (January to
June), and once during the second half (July to December), with at
least 60-days separating inspection dates (unless performed more
frequently than semi-annually). These facility inspections are
different from, and addition to, the stormwater discharge
characteristic monitoring at the outfalls required in Part IV B, C,
and D of this permit.
Response: The batch plant site has been inspected a minimum of once
weekly since 20 Jan 20. These inspections are housed in a separate
binder and promulgated to the USACE in RMS. Inspections include both
the environmental aspects as well as those of Good Housekeeping.
Additionally, the Above Ground Storage Tanks (ASTs) are inspected at
least once weekly. These inspections are housed in a separate binder.
A separate section in the SWPPP binder was not set up to address the
requirements noted in Part III, item 5. Effective 12 Jan 21, a
separate section has since been established in the SWPPP binder noting
these inspections.
c. Part III, item 7 - Responsible Party. The SPPP shall identify a
specific position or positions responsible for the overall
coordination, development, implementation, and revision of the SPPP.
Responsibilities for all components of the SPPP shall be documented
and position assignments provided.
Response: Responsible party noted on Permit Name/Ownership Change Form
was not current. This was corrected and now reflects current
personnel/positions responsible.
d. Part III, item 8 - SPPP Amendment and Annual Update. The permittee
shall amend the SPPP whenever there is a change in design,
construction, operation, site drainage, maintenance, or configuration
of the physical features which may have a significant effect on the
potential for the discharge of pollutants to surface waters. All
aspects of the SPPP shall be reviewed and updated on an annual basis.
The annual update shall include:
(a) an updated list of significant spills or leaks of pollutants for
the previous three (3) years, or the notification that no spills have
occurred (element of the Site Overview).
Response: Incident section in SWPPP binder has been renamed "Spills"
and placed within Site Overview section. Yearly inspection
documentation pages are also included.
(b) a written re -certification that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges (element of
the Site Overview).
Response: Stormwater outfall recertification section has been added to
SWPPP binder. The recertification letter is current.
(c) a documented re-evaluation of the effectiveness of the onsite
stormwater BMPs (BMP Summary element of the Stormwater Management
Frmily owned and operited since 1987 www.rcconstnet
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Strategy).
Response: Stormwater Management Strategy, BMP-specific section added
to SWPPP binder. Data updated and pages amended pursuant to the
section.
(d) a review and comparison of sample analytical data to benchmark
values (if applicable) over the past year, including a discussion
about Tiered Response status. The permittee shall use the Division's
Annual Summary Data Monitoring Report (DMR) form, available from the
Stormwater Permitting Program's website (See `Monitoring Forms' at
deq.nc.gov)
Response: RC Construction has contracted with Microbac Laboratories to
perform analytical testing. The first test was completed 13 Nov 20.
Subsequent tests will occur quarterly starting Jan 2021. Testing
results are housed in SWPPP binder.
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.
Response: RC Construction has contracted with Microbac Laboratories to
perform analytical testing. The first test was completed 13 Nov 20.
Subsequent tests will occur quarterly starting Jan 2021. Testing
results are housed in SWPPP binder.
Other Observations:
Does the plan include a list of significant spills occurring during
the past 3 years?
Response: One spill was noted in section within the SWPPP binder;
however, it was not in the format acceptable to the inspector. This
has since been corrected.
Does the plan include a list of Responsible Party(s)?
Response: The plan was not current. It has since been updated.
Is the plan reviewed and updated annually?
Response: Any changes (e.g., silt fence replacement, BMP adjustments,
etc.) made to the plan were annotated on the site map. These changes
were added and dated on the site map to reflect the same during the
course of the last year. A separate map is now a part of this section.
This so the inspector doesn't have to page back and forth between
tabs.
Does the plan include a Stormwater Facility Inspection Program?
Response: Prior to the inspection, the weekly Environmental Stormwater
1-amily owned and operated since 1987
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Inspection was thought to be acceptable. The current plan now includes
a separate Stormwater Facility Inspection Program. The SWPPP binder is
up to date with this inspection program.
Has the Stormwater Pollution Prevention Plan been implemented?
Response: Yes.
Has the facility conducted its Analytical monitoring?
Response: Yes. RC Construction has contracted with Microbac
Laboratories to continue analytical testing of the site's outflow
water. This was implemented before the 9 Dec 2020 NCDENR inspection.
If there are any questions regarding this response, please contact the
undersigned at [phone], or Mr. Edward Murchison, Chief Quality Control
Manager, ([e-mail]) at [phone].
Sincerely,
Edward B. Murchison
Chief, Quality Control Manager
RC Construction
ATCH: NOV-2011-PC-008
Family owned and operited since 1987
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