NCG140003_NOV (CO Copy)_20170911

Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
August 25, 2017
CERTIFIED MAIL #7015 0640 0005 8164 4283
RETURN RECEIPT REQUESTED
Mitchell Childers, Jr.
Childers Concrete Company
200 Wise Avenue
High Point, NC 27260
Subject: NOTICE OF VIOLATION
NOD-2016-SP-0004 (Initial Violations 8/8/2016,
Permit No. NCG 140003
Childers Concrete Company
Guilford County
Dear Mr. Childers:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
Violations Added 8/25/2016)
On August 22, 2017, Ryan Swaim of the North Carolina Department of Environmental Quality
conducted a multimedia inspection of the facility located at 200 Wise Street in High Point.
Multimedia inspectors are required to conduct their inspections and report any perceived
deficiencies to the division responsible for maintaining permits in that specific area so that
determination can be made as to how to proceed. This facility is covered under General Permit
No. NCG 140003 which allows the discharge of stormwater point source discharges associated
with activities classified as Ready Mixed Concrete and like activities to the surface waters of
North Carolina.
Compliance History:
This facility received an initial Notice of Deficiency (NOD) on August 8, 2016 following
deficiencies discovered during a multimedia inspection and subsequent follow-up. At that time
the facility had not developed and was not maintaining a Stormwater Pollution Prevention Plan
(SPPP). Since receiving the NOD, .the .facility has developed and has been maintaining an SPPP.
No Qualitative or Analytical Monitoring has been performed to date.
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Childers Concrete has made significant improvements since August of 2016 but the following
observations and violations were noted during NCDEQ's inspection and subsequent file review:
1. Stormwater Discharge - Qualitative Monitoring:
General Permit NCG 140000, Part IV Section C requires qualitative monitoring be
conducted twice per year following the established guidelines. No qualitative monitoring
has been conducted since the initial deficiency was discovered in August of 2016.
2. Stormwater Discharge - Analytical Monitoring:
General Permit NCG 140000, Part IV Section A requires the facility to conduct analytical
monitoring twice annually at each of the facilities stormwater outfalls. Since the initial
NOD was issued in August of 2016, this facility has not been providing Analytical
Monitoring as the permit requires.
Required Response
Accordingly, you are directed to respond to this letter in writing within 30 calendar days of
receipt of this Notice. Your response should outline how the violations will be addressed and
should be- sent to this office at the letterhead address and include the following:
1. Provide Qualitative Monitoring of Stormwater Outfalls twice annually. Keep records in
the SPPP binder. (Explain how this issue will be addressed.)
2. Provide Analytical Monitoring of Stormwater Outfalls per permit requirements defined in
Part IV, Section A. TSS and pH are required parameters. Contact a qualified testing
facility. They will provide sampling kits for collection of analytical samples and can
assist with understanding how samples will need to be collected and shipped or delivered
to the lab for testing. Once results are received for each monitoring period, forward a
copy to this office at the address listed on the letterhead. (Explain how this issue will be
addressed.)
Thank you for your attention to this matter. The violations listed in this NOV are continued
violations and part of the initial violations described in the NOD issued on August 8, 2016. As
these are deficiencies that have prior citation, this office may consider a recommendation for
enforcement to the Director of the DEMLR (Division of Energy, Minerals, & Land Resources)
regarding these issues and any future/continued violations that may be encountered. This office
requires that the violations, as detailed above, be abated immediately and properly
resolved. Environmental damage and/or failure to secure proper authorizations have been
documented on the subject tract as stated above. Your efforts to undertake activities to bring the
subject site back into compliance is not an admission, rather it is an action that must be taken to
begin to resolve ongoing environmental issues.
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Pursuant to G.S. 143-215.6A, these violations and any future violations are subject to a civil
penalty assessment of up to a maximum of $25,000.00 per day for each violation. Your
above -mentioned response to this correspondence, the degree and extent of harm to the
environment and the duration and gravity of the violation(s) will be considered in any civil
penalty assessment process that may occur. Should you have any questions regarding these
matters, please contact Glen White at [phone].
Sincerely,
Matthew E. Gantt, P.E.
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
cc: DEMLR — WSRO
(Lisa Edwards, P.E.) DAQ — WSRO
(Bethany Georgoulias) DEMLR Stormwater Permitting Unit — Raleigh
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