NCG020150_Emailed NOV Response NOV-201-OC-003 (Attachment)_20220103

HEDRICK
INDUSTRIES
December 28, 2021
Certified Mail: 70153010000192896589
NCDEQ — Division of Water Resources
Landon Davidson — Regional Supervisor
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Notice of Violation Response
NOV-201-OC-0003 (Incident #202102252)
Dear Mr. Davidson,
This letter is in response to the NOV received by BV Hedrick Gravel and Sand Company from NCDEQ
— Division of Water Resources on December 17, 2021. Grove Stone and Sand stands by our original
statement made to DWR via our phone conversation on December 15th, 2021 that the oil sheen identified
in the Swannanoa River by DWR on December gch and December 9th was not from our location. The
GSQ staff was notified by DEQ on December 9th that DWR had noticed an issue and would like for us
to do an internal site inspection to determine if any oil or sediment was leaving our site. Jason Conner,
Land Manager, and David Shelton, Superintendent reviewed all our basins and checked all erosion
control measures and it was determined that no sediment or oil was leaving our site on December 91h.
Shawna Riddle with DEQ also did an inspection of our facility on December 101h and concluded that
Grove Stone and Sand was in compliance with their mining permit and stormwater permit NCG020000.
DWR again notified DEQ on December 13`h of there findings on December 11'h. Grove Stone staff
again did an inspection of our facility and found no oil sheen or sediment discharges.
The basin in question is located adjacent to our office and collects stormwater and some process water
from the plant. The basin also catches any rainwater and water from our dust suppression that is
required by our air permit. This basin is also tested for non -polar oil and grease. The basin collects any
runoff from our maintenance facility. The NCG020000 permits allows us to discharge 15 mg/L of non -
polar oil and grease during a discharge event. Five samples have been taken this year at this basin for
non -polar and grease and all samples have resulted in non -detectable limits. The samples were taken on
1-5-2021, 8-20-2021, 9-17-2021, 12-14-2021, and 12-21-2021. All the samples were processed by Pace
Labs.
Required Response and Corrective Action Questions:
1. There have been no unpermitted discharges of petroleum products to the surface waters from
primary and secondary sources.
Office: 828.686.3844
Cell: 828.712.9009
iMMe rickind_conr
www.hedrickind.com

2. The outfall is a secondary basin that catches any runoff from the plant wash water and dust
suppression from the plant. This basin also catches stormwater runoff from the maintenance
facility area. Depending on the amount of water used at the plant and if any type of malfunction
that may have occurred an excess of water may have been present. This basin is also used as a
backup to treat water if something happens at the plant. The basin typically takes 5 to 7 days to
fully drain due to the design.
The basin is checked weekly as required by our NCG02000 permit. Once the basin reaches 25
percent capacity the basin is cleaned of sediment and all stone is removed around the riser and
replaced. Shawna Riddle checked our weekly basin inspection paperwork and all basins during
her inspection on December 10, 2021.
3. The release was not related to any UST incident. There has not been a UST located at this
Iocation since 1997. Grove Stone and Sand does not believe there was a release of petroleum
from our site. Our testing results have consistently shown non -detectable limits of non -polar oil
and grease and during our visual inspections we have not seen any sheen present in the surface
waters. Grove Stone has responded each time a compliant has been received from DWR or DEQ
with a visual inspection and our staff has not seen an oil sheen.
Grove Stone staff has only been notified of the findings a day after the inspections. During my
meeting with DWR staff on December 15'h and through my conversations with DEQ staff,
inspectors are welcome on our property at any time and GSQ staff are more than willing to
accompany the inspectors to look at any issues they may have discovered. We also requested
that DWR staff let us know immediately when an issue or finding has occurred allowing us to
address and inspect the issue real time not a day later. By the time we are notified of there
findings and do our inspection we have not seen a sheen or the sediment issues DWR is
describing.
4. Grove Stone staff is available for inspections on January 12, 13, or 14'h.
Current Actions taken by Grove Stone
On December 20t1i Grove Stone staff decided to be pro -active and pump any remaining water in outfall
#1 and replace all the stone around the riser. The water was pumped to our slurry pump which then
pumped the water up to our settling ponds. DWR did an inspection on December 20'h in the afternoon
and notified Grove Stone December 21, 2021 at 11:52 am that an oil sheen was present in the basin.
GSQ staff had noticed the oil sheen December 21 and took a water sample that resulted in nondetectable
oil and grease from the basin discharge. GSQ staff also placed absorbent socks around the riser to soak
up any potential oil residue. On December 23, 2021 GSQ widened outfall 1 to increase its capacity.
The stone again was removed and replaced with 57's and 78m to help with filtration. As of December
2$1h, the basin has been fully cleaned out and redesigned to better handle any stormwater or residual
water from the plant.
Office: 828.686.3844
Cell: 828.712.9009
ico nner@ hed rickiod_com
www.hedrickind.com

Should you have any questions regarding this report, please contact Jason Conner at [phone].
Sincerely,
4- G---
Jason Conner
Vice President — Land Management
office: 828.686.3844
Cell: 828.712.9009
icon nerPhedrickind.com
www.hedrickind.com