SW NOV - Leonard Block Company

Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
August 28, 2017
CERTIFIED MAIL #7015 0640 0005 8164 4276
Attn: Dwayne Richardson
Leonard Block Company
2390 Midway School Road
Winston-Salem, NC 27107
Subject: NOTICE OF VIOLATION
NOV-2017-SP-0011
Permit No. NCG 070197
Leonard Block Company
Davidson County
Dear Mr. Richardson:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
On August 17, 2017, Charles Gerstell, Environmental Senior Specialist with the North Carolina
Department of Environmental Quality — Division of Waste Management (NCDEQ — DWM)
conducted a multimedia inspection at the facility located at 2390 Midway School Road in
Winston-Salem. The inspection discovered several deficiencies regarding the facilities industrial
stormwater permit.
This facility holds General Stormwater Permit NCG070197 to discharge stormwater from
industrial activity associated with Stone, Clay, Glass, and Concrete Products [SIC 321 under
the National Pollutant Discharge Elimination System (NPDES). The permit became effective
June 1, 2013 and expires on May 31, 2018. A copy of the current permit is required to be
maintained with the Stormwater Pollution Prevention Plan (SPPP) documents. The current
permit was available for review and was included in the SPPP at the time of Mr. Gerstells
inspection.
This facility was required to develop and maintain a Stormwater Pollution Prevention Plan
(SPPP). A Notice of Deficiency (NOD) was issued to this facility on September 2, 2016. It is
noted that significant improvements have been made to the facilities records and to the facility
condition itself since that date. At the time of the multimedia inspection on August 17, 2017, the
facility had not provided required annual employee training, had not been providing bi-annual
qualitative monitoring, had not updated some areas of the SPPP and had not been signing annual
certification of the SPPP.
State of North Carolina 1 Environmental Quality 1 Energy, Mineral and Land Resources
Winston-5alern Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem. NC 27103
336 C!6 9800

The following observations and violations were noted during the NCDEQ multimedia
inspection:
Stormwater Pollution Prevention Plan:
• NCG 070000, Part II Section A requires the permittee to develop and implement a
Stormwater Pollution Prevention Plan that includes items 1 thru 9 of Section A. While an
SPPP was provided, it was found to be deficient. The facility was deficient with annual
certification of the SPPP as well as annual updating of other areas of the plan, and has not
provided or documented annual employee training as required.
Qualitative Monitoring (Bi -Annual)
• NCG 070000, Part II Section C requires qualitative monitoring to be conducted twice
annually at each outfall. The facility was deficient in that it did not monitor twice
annually as required and has not documented or provided monitoring at each outfall.
Representative Outfall Status has not been determined and it appears that this facility has
outfalls that do qualify. Monitoring requires the person conducting monitoring to go to
each outfall twice each year and document on the qualitative monitoring form what was
observed. It is a visual inspection only. Fill out a separate form for each outfall. Please
begin monitoring twice (2) annually as permit requires.
Your Reauired 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:
• Stormwater Pollution Prevention Plan: In your response, tell us how you will address
the deficiencies of each of the 9 items of Part II, Section A of the permit and let us know
when you expect to have this issue corrected.
• Qualitative Monitoring: Begin qualitative monitoring for each outfall. Monitoring
should identify color, odor, clarity, floating solids, suspended solids, foam, oil sheen,
erosion or deposition and any other obvious indication of pollution. A photo taken of the
outfall at the time of inspection provides excellent documentation. Your response should
include your expected compliance with bi-annual monitoring.
For assistance with determining outfall locations and which outfalls will require
monitoring as well as assistance with other questions related to industrial stormwater,
contact Glen White at 336-776-9660.
Thank you for your attention to this matter. Failure to correct the violations may result in this
office's recommendation for enforcement by the Director of the DEMLR (Division of Energy,
Minerals, & Land Resources) if the issues and any future violations continue. 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.
State oFNorth Carolina rnvlronmentai 2uatity J 8ncrgy, Mineral and Land Resauees
Winston-Satem Regional Office 1 450 Hanes Mill Road, Suite• 3001 Winston-Salern, NC 27103
336 716 9800

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
Qualitative Monitoring Forms (2 sided)
cc: DEMLR— WSRO
DEMLR — Stormwater Permitting Unit
DAQ - WSRO
State of North Carolina 1 Environmental Quality 1 Energy,Mincraland Land Resoarees
Winston-Salem Regional Office 1 450 Hanes Mill RUad. Suite 3601 WinatorrSAem, NC 27103
336 776 9800

Compliance Inspection Reoort
Permit: NCG070197 Effective: 06/01/13 Expiration: 05/31/18 Owner: CHB Leonard
SOC: Effective: Expiration: Facility: Leonard Block Company
County: Davidson 2390 Midway School Rd
Region: Winston-Salem
Winston Salem NC 27107
Contact Person: C H B Leonard Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/17/2017
Primary Inspector: Charles Gerstell
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 09:58AM Exit Tlme:. 12:48PM
Phone: [phone]
Reason for Inspection: Routine - Inspection Type: Compliance Evaluation
Permit Inspection Type: Stone, Clay, Glass, and Concrete Products Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
0 Storm water
(See attachment summary)
Page: 1

Permit NGG070197 Owner - Facility:C HB Leonard
Inspection Date: 08/17/2017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
As noted under the "Permits and Outfalls" section of the report. It appeared that the facility may have as many as 3 - 4
outfalls on site. It appeared that material from the sand and gravel stockpile area located on the opposite side of Brushy
Creek had deposited into the creek. In the previous inspection report, Mr. Glen White requested that an outfall be provided
in this location and the old retaining wall be repaired or a berm constructed to minimize the erosive effect and for saftey.
Since the last inspection, five concrete butresses had been placed in this location to address Mr. White's concerns. Mr.
Dwayne Richardson stated that he was needing assistance from DEMLR to inform him where the butresses should be
placed to address Mr. White's conerns. Mr. Richardson's request for guidance will be forwarded to DEMLR via this
inspection report.
It appeared that aggregate from stockpiles were entering multiple stormdrains located directly adjacent to the production
building on the west side. This condition may be considered a release of wastewater which could trigger requirements in the
140000 series permits to nclude analytical monitoring. This concern will be referred to DEMLR staff. This inspection report
will also be referred to DEMLR staff to determine status of compliance in reference to the Notice of Defciency that was
issued to Leonard Block Company on September 2, 2016.
Page: 2

Permit: NCG070197 Owner - Facility:C HB Leonard
Inspection Date: 08/17/2017 Inspection Type : Compliance Evaluation Reason for VIsk: 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 (USGS) map?
0 ❑ ❑ ❑
#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?
❑ 0 ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ 0 ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ 0 ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 ❑ ❑
Comment: It appeared that portions of the SPPP that were not present during the previous insDection were
Provided during the inspection performed on 8/17/17. Although a list of significant spills was not
Provided, Mr. Richardson and Ms. Miller explained that there had been no such spills over the
Past three years. Facility still needs to document employee training as reauested on the
previous inspection report. This was discussed with Mr. Richardson and Ms. Miller.
Responsible party information was updated since the last inspection to show Mr. C.H.B. Leonard
as the sole responsible party. For annual updating, many portions of the document are still in
need of updating. Annual updating of the SPPP was discussed with Mr. Richardson and Ms.
Miller.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Yes No NA NE
❑■❑❑
Comment: No qualitative monitorina has been Derformed in suite some time. Ms. Miller stated that facilit
staff had requested guidance in reference to the required testing on the "Response for Notice of
Deficiency" submitted by Leonard Block Company. Inc. and received by DEMLR on October 4.
2016. Ms. Miller was able to locate some blank sampling forms. Methods for monitorina and
proper documenting on sampling forms was discussed with Mr. Richardson and Ms. Miller. It is
recommended that DEMLR staff contact the facility to provide additional guidance.
Analytical Monitorina Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ M ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ M ❑
Comment: The facility is currently not required to perform analytical monitoring as the facility does not use
55 -gallons of motor oil per month.
Page: 3

Permit: NCG070197 Owner - Facility:C HB Leonard
Inspection Date: 08/17/2017 -- Inspection Type : Compliance Evaluation Reason for Visit: Routine
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0111111
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it property documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 1:11:1
Comment: Ms. Miller Presented a copy of the facility Dermit durina the inspection. It aooeared that onlv one
outfall had been monitored in the Past but inspection appared to reveal that there may be as
many as three to four separate outfall locations leading from multiple stormdrains on site.
Outlets from stormdrains on the west side of the facility appeared to lead to Brushy Fork.
However, outfalls leading from the storm drains on the west side of hte facility could not be
observed due to safety concerns. Stormdrains observed on the east side of the facility aooeared
to daylight at a concrete wall located adjacent to an unnamed tributary to Brushy Fork.
Page: 4