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HomeMy WebLinkAboutNCG140463_(Signed) NOV & Insp Rpt_20240321 `�.S••TATE., ROY COOPERS Governor 2 ELIZABETH S.BISER Secretary WILLIAM E.TOBY VINSON,JR NORTH CAPOUNA !,tierim Dircoar Environmental Quality March 21, 2024 CERTIFIED MAIL: 7017 0190 0000 2486 7094 RETURN RECEIPT REQUESTED Raleigh Concrete, LLC Attn: Jose Juan Plascencia Sanchez 1938 S. Wilmington Street Raleigh, NC 27603 Subject: NOTICE OF VIOLATION # NOV-2023-PC-0579 Raleigh Concrete, LLC Raleigh Concrete, Certificate of Coverage-NCG140463 NPDES Stormwater General Permit-NCG140000 Mr. Sanchez: On November 17, 2023, Thad Valentine from the Raleigh Regional Office of the Division of Energy, Mineral and Land Resources, conducted a site inspection for the Raleigh Concrete facility located at 1938 S. Wilmington Street, Wake County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Gab Jackson (Plant Manager)and Karem Dudley were present during the inspection and their time and assistance is greatly appreciated. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Walnut Creek, a Class C;NSW waterbody in the Neuse River Basin.The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit-NCG140000, Certificate of Cove rage-NCG140463. Please note that this is the second time this Notice of Violation (NOV) has been sent.The first NOV was sent on December 4, 2023 and was returned as undeliverable. As a result of the site inspection, the following permit conditions violations are noted: 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has not been developed, recorded, or properly implemented. Inspection report attached 2)Qualitative Monitoringa Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 3)Analytical Monitoring Analytical monitoring has not been conducted and recorded in accordance with permit requirements. Other Observations: Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. REQ North Carol€na Depariment of Environmental Quality Division of Energy,hiiner.il anri Land Resources e::�� ;w Raleigh Regional Office 11628!vial!Service Center 13800 Barrett Drive I Raleigh,North Carolina 27h09 o.p.e .1rk wO ft� /`� �I4.7�7E.4200 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 violations have occurred as well as a Plan of Action to prevent these violations from recurring. Thank you for your attention to this matter. This office requires that the violations, as detailed above, 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 Thad Valentine or myself at(919)791-4200. Sincerely, William H. Denton, IV, PE Regional Engineer-RRO Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality uality Enclosure CC.' Brittany Cook-General Permit Coordinator Mike Lawyer, Supervisor-Stormwater Permitting Program RRO-Land Quality Section, Stormwater Files-NCG14000 North Carolina Department of Envirnnmental QLtality ; Division of Energy.Mineraf and Ladd Resources ERaleigh Regional Office 11628 Mail Set vice Center 13800 Barrett Drive i Raleigh.North Carolina 27609 _s Compliance Inspection Report Permit:NCG140463 Effective: 07/01/22 Expiration: 06/30:27 Owner: Raleigh Concrete LLC SOC: Effective: Expiration: Facility: Raleigh Concrete County:Wake 1938 S Wilmington St Region: Raleigh Raleigh NC 27603 Contact Person:Brenda Roque Title: Phone:919-339-8663 Directions to Facility: exit 298E off of 140, left of s saunder st ;eft on penmarc dr,keep straight on water works st.,left on fayetteville st left of south wilmington,destination on right. System Classifications: SWNC Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 1107+2023 Entry Time 10:30AM Exit Time: 11 OOAM Primary Inspector:Thaddeus W Valentine Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Ready Mix Concrete StormwaterlWastewater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 4 Permit: NOG140463 Owner-Facility:Raleigh Concrete LLC Inspection Date: 11/17/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: A review of the documents revealed that there were no list of significant spills,or the lack there of, listed in the stormwater pollution plan (SP3).Provide a spill log that covers any spills for the last 3)years in the log and that notes either all the details and requird specifics of spills or write"No Spills"if there are none.Any spills that occur on site should be listed in the spill prevention and response plan with a detailed summery of corrective actions taken to clean up and dispose of the spilled materials and what was done to ensure it doesn't happen again.An ongoing spill was located on site at the oil and diesel storage located on the West side of the site.The materials were actively being spilled within the containment area and on the outside of that area at the drain port that had no lock.The spills in the containment area as well as the spill on the outside had not been cleaned up for an extended amount of time, if ever.The spills and leaks were not documented as part of the significant spills documentation and the area was not listed on any check list as required by the preventive maintenance and good housekeeping plan requirements. The areas should be cleaned up and all corrective actions, including material disposal proced u res,should be documented The facility has not documented any feasibility evaluation for the site that would take into account any areas that need work to prevent stormwater contamination There is a poly tank vessels that contains materials, used in the facilities process, located outside of the secondary containment area that should be located within that area.There are containment areas and vessels that have ports without the required locks that should be locked. Once the required corrections have been made,those actions should be documented within the SP3.Any and all drums, buckets,poly tanks and any kinds of containers should be stored properly with lids or pluggs when not in use and should be stored inside or within secondary containment. The North side of the vehicle maintenance building has a large spill were petroleum materials area improperly stored and allowed to leak and leach onto the ground.The building is used for vehicle maintenance support for the equipment used for the Raleigh Concrete facility There has not been a thorough assessment of areas of the facility with the potential for spills and there are no action plans for those areas. Included in those areas should be the equipment fueling area adjacent to the Diesel aboveground storage tank and the oil, waste oil and diesel containment area. Additionally the vehicle maintenance area should be included along with an action plan to deal with the large spill and improperly stored materials on the North side of the building and around the site and any new outfalls associated with the portion of the site should be identified with written notice of their locations. An assessment should be undertaken to evaluate the entire site to identify all potential areas for spills and provide an spill prevention and response plan for all those areas.Additionally,an action plan should be developed in case of a spill for each area.Any actions taken should be thoroughly documented A thorough preventive maintenance and good housekeeping plan should be developed to ensure that all areas of the site are being inspected, including the vehicle maintenance area, and that any problems are identified and corrected immediately.All actions taken should be documented within the plan. The water truck and the sweeper should both be part of this plan and if there are issues with that equipment, as there is now, it should be documented with notes of who was notified, when they were notified of the issue and what the plan of action is. The facility documents employee training, but doesn't have any training materials_Training materials should be used to train employees and those training materials should cover all the required objectives of the permit and not just spill prevention. Videos and handouts should be utilized to train employees on all aspects of the permit which are required Update the list of responsible parties to include any new or alternate employees for that facility Work on the stormwater facility inspection program. The facility doesn't have an inspection program that is detailed enough to capture all the areas on site that have the potential to pollute stormwater. No inspections of the site have been documented in the last year Overall the site has a considerable amount of issues with sediment leaving the site and oil and fuel spilled in muliple areas on site with no cleanup efforts.The equipment that helps keep the sediment from leaving the site is broke down with no Page 2 of 4 Permit: NCG140463 Owner-Facility:Raleigh Concrete LLC Inspection Date: 11r17f=3 Inspection Type,CompJance Evaluation Reason for Visit: Routine documented plan for repair.Additionally. there is vehicle maintenance activities taking place for this Facility on the adjacent property owned by the permit holder that serves as the vehicle maintenance building for Raleigh Concrete facility. Raleigh Concrete must include the vehicle maintenance building area in their permit and follow all the requiremnts of the permit for that area Any new outfalls associated with the vehicle maintenance area should be identified and written notification made to DEQ of additional outfall points. Cleanup of the large spill on the North side of the building and any other spills in that area must be taken care of on an expedited schedule. Raleigh Concrete may choice to permit that portion of the operation seperately under an NCG080000 permit. If so, that should be done on an expedited schdule.The vehicle maintenance facility will be considered part of the Raleigh Concrete facility operation until the seperate NCG08000O permit option is initiated and finalized, if you chose to take that alternate permitting route. Page 3of4 Permit: NCG140463 Owner-Facility:Raie gh Concrete U C Inspection Date: 11:1712023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑ #Does the Plan include a General Location(USES)map? E ❑ ❑ ❑ #Does the Plan include a"Narrative Description of Practices"? 0 ❑ ❑ ❑ #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? ❑ ■ ❑ ❑ #Has the facility evaluated feasible alternatives to current pract-ces? ❑ E ❑ ❑ #Does the facility provide all necessary secondary containment? ❑ E 130 #Does the Plan include a BMP summary? 0 ❑ 1111 #Does the Plan include a Spill Prevention and Response Plan (SPRP)? N ❑ 1111 #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ #Does the facility provide and document Employee Training? 0 ❑ 1111 #Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ #Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑ #Does the Pan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? M ❑ 1111 Comment: The SP3 wasayallable fior the inspection but there were parts missing and parts that needed updating. The environmental consultant was in th eprocess of updating the plan. Comments for this section can be found in the Summery section Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ Comment: Provided Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ N ❑ ❑ #Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 0 ❑ ❑ Comment: Analytical monitor'pn-q was not available and although vehicle maintenance activities exist on the property adjoining the Raleigh Concrete and is used as vehicle maintenance support for that facility, the Permittee doesn't knowledge it on their permit alAcation. Permit and Outfalls Yes No NA NE #Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ E ❑ ❑ #Were all outfalls observed during the inspection? 013 ❑ ❑ #If the facil'ty has representative outfall status, s it properly documented by the Division? ❑ ❑ N ❑ #Has the facility evaluated all illicit(non stormwater)discharges? 00 1111 Comment: The certificate of coverage was not available Page 4 of 4 a Raleigh Concrete Pictures 11/17/2023 } { r. Poly tank outside secondary r } 4 w Poly tank drain without lock - �_- � "2 . ; y - _ Secondary . . - area spillsand d . . lock �M���f{ry� .. L•4i ix.,\1 /yk�5" _ �~� f� ,!• ,r5� i � L �i. �],+'•Y�:�.irir7'' :_�. [� „a �}� C 'f3' �EAy !al'�� .'F � . ���RY :�{ - 1 �• .'+l�s} k.Y'JS';/';k 'r.f '�~ ��Y S� 4 �, .y {� ��,fy�.`4 JL �liyi.+ 1 Hr � ;iJ•�.I a ��of` + '�'�.�'' y r 3s _yam Secondary containment area with drums with open bung holes. Oil has overflowedcontainment � � x - � »l %\& r \z &K � \ r { . . Overflow int. the containment area - . \ - ` �� � - � Oil on top o drums from overflow a: « ...... - . Ir Stains from spills at vehicle maintenance area from improperly stored and maintained storage vessels 7 � - M �< . - - - ■ � � - j !