NCG140129_Email Illicit Discharge, Limit Violations_20221118

Carson, Brittany
From:Britton, Audrey <[e-mail]>
Sent:Friday, November 18, 2022 2:13 PM
To:Carson, Brittany; Valentine, Thad
Cc:Azarelo, James
Subject:\[External\] Durham - Ready Mix 17 - Violations
Attachments:Stormwater Inspection Report - Ready Mix 17 - November 2022.pdf
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Good afternoon,

I am emailing about a facility, Ready Mix 17, on 3411 NC Highway 55 in Durham. I inspected this facility and observed a
few violations that may require State involvement.

First, they are reporting their stormwater samples as wastewater, using the wastewater DMR. Their discharges are not
be comingled, so this seems to be an error. All the records I reviewed showed this manner of reporting.

Second, their wastewater pond is overflowing into the woods. I checked pH and conductivity, which were 11.6 and 1374
respectively. This may be considered a wastewater discharge (without notification), and I would think something needs
to be done about their wastewater pond.

I have attached their inspection report to this email. I can provide additional information as necessary. Please let me
know what you determine so that I can check for compliance at my next inspection, which will be in six months.

Thank you,

Audrey

Audrey Bales Britton
Environmental Planning & Compliance Coordinator
City of Durham, NC Public Works | Stormwater Division | Water Quality
101 City Hall Plaza Durham, NC 27701

P: 919.560.4326 x30216 | F: 919.560.4316
[e-mail]
http://www.durhamnc.gov/stormwater

Please use our Email ([e-mail]) or Hotline (919.560.SWIM) for reporting Water Quality Issues.

**E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties**

1

City of Durham Stormwater Inspection Report for 22-ISWI-177
Facility Name Ready Mixed Concrete Company #17 Dat 10/25/2022 Time 11:30
Facility Location 3411 NC Hwy 55 Inspector Audrey Britton
Inspection Esc or Reggie Lunsford Inspector Phone [phone]x30216
Facility Type Ready Mix Result violation Referred to NC DEMLR
Asst. Inspector(s) Inspection Type Routine
Inspection Findings
Is the site free of illicit discharges? No
Is the site free of illicit connections?
Yes
Is the site generally in good condition?
Yes
Are pollutant containers stored properly? No
Are automotive activities conducted in compliance? Yes
Does facility have proper spill response?
Yes
Inspector's Comments
Is trash/solid waste handled and stored appropriately?
Yes
Does facility have a NPDES Permit if required?:
Yes
Is facility SPPP complete, if required?
Yes
Has facility conducted runoff monitoring, if required?
No
Has facility conducted self -inspections, if required?
Yes
Has facility conducted employee training, if required?
Yes
The facility operates as a ready -mix concrete plant under a NCG140000 Permit. The most recent General Permit went into effect July 1,
2022 and will expire June 30, 2027. A copy of the most recent Certificate of Coverage (COC) was not available. The facility should follow
up with NCDEQ to ensure receipt of the COC.
he Stormwater Pollution Prevention Plan (SWPPP) and associated records were available for review at the time of the inspection. The
WPPP was last updated February 14, 2018. The facility should review the SWPPP and make any necessary updates. Required annual
ignatures were present in the SWPPP. Records must only be maintained for five years. Older records may be removed from the SWPPI
nd filed away.
Please note that the NCG140000 Permit requires quarterly sampling of stormwater discharges. In addition, where applicable and
approved by NCDEQ wastewater discharges must also be sampled quarterly. Discharge Monitoring Reports (DMRs) must be submitted
to NCDEQ per the requirements listed in the Permit. If no discharge occurs during the sample period, the DMR must still be submitted
with a designation of "No Discharge." Based on review of available records, it appears the facility has not sampled stormwater
)orted for stormwater and wastewater samples, the facility must accurately report discharges and distinguish between
stormwater and wastewater discharges. Based on facility layout, stormwater and wastewater should not be comingled at this
location, and therefore they must be reported separately. The facility must comply with all aspects of their Permit, including sampling
and reporting.
e Permit also requires the facility to report other occurrences such as bypasses (Part 1). See below for applicability.
It is the facility's responsibility to be familiar with and compliant with all sections of their NCG140000 Permit.
Operations include those typical of ready -mix plants, such as delivery, storage, and mixing of raw mate rials,onsite fueling, and truck
washing and drum cleanout.
J materials, such as cement, fly ash, and rock, are stored in piles or silos throughout the facility. Dust is generated from onsite
rations. The facility would benefit from regular sweeping, particularly of the paved areas near the entrances. Dust and sediment
Page 1 of 3

City of Durham Stormwater Inspection Report for 22-ISWI-177
was observed in the curb near both entrances. Based on the location of the outfalls, sediment leaving the site at the entrances may
not be represented in stormwater samples.
Liquid additives are stored in bulk storage tanks, which are primarily located within a concrete containment wall. The containment area
does have a valve, which was recently broken off. The drain has been temporarily plugged. The valve must be repaired to prevent
future onsite releases from the containment area. Releases from the containment would need to be reported, so it is in the facility's
best interest to have a permanent solution for the broken valve.
Diesel fuel is stored in a bulk tank in the north portion of the facility, and is used for onsite fueling of cement trucks. The tank and fuel
dispenser are positioned within a containment wall and under a metal awning. A complete spill kit is located at the fueling station.
Trucks are washed in the central portion of the property. The grading of the facility directs truck wash water to a collection pit. Sludge
collected in the pit is periodically scooped out and allowed to dry onsite. Dried material is then removed and disposed of offsite. Excess
liquid from the collection pit is containerized and disposed of offsite.
A wastewater pond is located at the north portion of the facility. The pond is used for collection of drum rinse water. Reportedly,
excess liquid in the pond may be pumped out and containerized, however, facility staff indicated this was a rare occurrence. At the
time of the inspection, the wastewater pond appeared very full, and clear boundaries could not be seen. Upon further inspection,
wastewater could be seen extending north into the woods. The water had a pH of 11.6 and conductivity of 1374 uS. While the
wastewater did not appear to be reaching the municipal storm drainage system, the wastewater overflow represents a reportable
release and a violation of the Permit. Wastewater must be contained, and releases must be documented and reported.
Note: As a follow up, several stormwater structures were screened on November 4, 2022 to determine if the release had
reached either the storm drainage system or a nearby stream. Based on field observations at that time, it did not appear that
the release had reached those structures.
The facility must demonstrate full compliance with their Permit, including sampling, reporting, and containment. The facility will be
reinspected in six months.
A copy of this report is being forwarded to NCDEQ for their review.
Facility overview.
Truck wash water flows toward a collection pit.
Page 2 of 3

City of Durham Stormwater Inspection Report for 22-ISWI-177
Wash water collection pit is scooped out as necessary. Sludge is
allowed to dry onsite then disposed of.
Additive fluid tanks are positioned within concrete containment wall.
Wastewater is not contained on the north side.
-- j
Fuel tank for onsite fueling of cement trucks. A spill kit is located at
the fueling site.
y�
Wastewater pond for truck cleanout.
Wastewater overflow in the woods at the north of the property. pH
was measured as 11.6.
Page 3 of 3