20111044 Ver 2_NOV-2017-OC-0006 Response_20171128

ROADMARK CORPORATION
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November 17, 2017 ---
Amy Chapman "! � v - � 2017
Transportation Permitting Branch
NC Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Notice of Violation
NOV-2017-OC-0006
BIMS No.201701621 a01� IJ�-F�{
TIP I-3819 A- Iredell County
Dear Ms. Chapman:
We are in receipt of the above-referenced Notice of Violation and have reviewed the incident
and the meeting held at the offices of Zachary Construction with Donna Hood of the NC Division of
Water Resources. During that meeting our crew chief, Tracy Alien and I went over the incident,
acknowledged that Roadmark was a[ fault antl made it clear that this was an aaident based in part on
not thinking through the consequences (Mr. Allen) and insufficient awareness and training from
Roadmark.
As an interim and immediate step, Roadmark supervisors have discussed this incident with all
crew chiefs and pointed out ways to avoid spills and discharges. These include using containment,
performance of tasks at appropriate locations and immediate response with litter/gravel to absorb any
liquids, as well as proper disposition of resulting waste. We recognize tha[ al[hough the materials in the
quantity discharged do not provide a health hazard we need to raise the awareness of our labor force
and assure that this type of incident does not occur in the future.
We are working with counsel to develop a full spill response policy, but during that time we are
using the attached information, developed for Smokey Mountain Parkway work. Roadmark has safety
and policy training for all employees scheduled for March 12 through March 14, 2018 and we will
indude a session devoted to spill prevention and remediation. When the exact time and date are set we
will extend an invitation to the Department to have a representative present to assure all issues are
addressed to the DepartmenYs satisfaction.
Again we express our regret for this incident, accept full responsibility and commit to training
and policies that should prevent any such occurrence in the future. Roadmark has worked hard for
nearly 40 years to maintain its reputation for quality and integrity and we view this area as important to
that commitment. We also thank Ms. Hood for her prompt and fair handling of the meeting and hope
that the Department will take our remedial actions into account in determining any further
consequences.
/
S' �
Dav' osenthal,
General Counsel
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ROADMARK CORPORATION
Material Spill Prevention and Action Plan
Great Smoky Mountains National Park
The materials to be used on this project which could disperse upon
spill are polyurea, alkyd thermoplastic and glass beads. The polyurea
contains no lead or other contaminants. The thermoplastic is a powdered
alkyd based product that contains no heavy metals and prior to application is
subjected to high temperatures that convert it to a liquid which mechanically
adheres to the highway surface. The beads are silicone and contain no
contaminants.
Despite the lack of contaminants, the nature of the surroundings
requires that best practices be followed to avoid any spills. Tank fillings
should be done, to the extent possible, off of the Parkway. Where refilling is
done on the Parkway the vehicles will be moved off of the roadway (but not
onto grass surfaces) where that can be done safely and packaging materials,
boxes and drop clothes will be deployed to avoid leakage. Care will be
taken to dispose of packaging materials offsite. All tank fitting, valves,
drains and stopcocks shall be inspected to assure they are tightened and not
dripping during operations. Thermoplastic and beads should be covered
when not in use to avoid leakage through tears in plastic packaging.
In the event of a spill of any of these materials, the following procedures
are to be followed:
1. Any injuries resulting from the spill should be addressed in accordance
with standard Roadmark safety procedures.
2. Immediately secure the spill area, placing appropriate traffic control and
pedestrian area protection.
3. Contain the spill to the minimum physical area. In the event of heated
materials, care should be taken that non-flammable materials are utilized
for containment and that employees maintain standard safety procedures,
including appropriate protective gloves, during the procedure.
4. If the material is in non-liquid form it will be swept and placed in plastic
bags. If the material is in liquid form it will be shoveled into boxes. In

either case 50-gallon empty drums can be used for temporary storage
until appropriate disposal containers are available.
5. In the event of a paint spill on the asphalt surface, the paint will be
contained using an inert absorbent material such as sawdust, sand or oil
dry. This material should them be placed into boxes or plastic bags for
disposal off-site. The affected area should then be flushed with a
minimal application of water and the resulting fluid wiped with rags to
complete the smear removal.
6. Care should be taken to minimize any damage to plant life if any spill
occurs off-road, including shoveling deeply enough to assure that any
seepage below the surface has been fully removed.
7. The Roadmark Safety Officer should be informed of the spill as soon as
practicable.
8. All materials are appropriate for disposal in commercial dumpsters or
waste disposal sites, subject to any applicable disposal permits or
licenses. There are no hazardous waste disposal rules or regulations that
pertain to any of these materials, however dried paint rags should not be
exposed to flames to avoid release of carbon monoxide or carbon
dioxide.