RC Construction NOD Response

RECONS1RUCtION CO. INC. P. o. BOX 1998
818 WALNUT STREET
GREENWOOD, MS 38935-1998
[phone] PHONE [phone] FAX
August 1; 2017
State of North Carolina, Environmental Quality
Department of Energy, Mineral, and Land Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
ATTN: Timothy L. LaBounty, PE
RE: NOTICE OF DEFICIENCY (NOD -2017 -PC -0205)
NPDES General Permit NCG140000
RC Construction Company, Inc., Certificate of Coverage NCG140424
Cumberland. County
AUG 7 2017
Subject: Response to NOD -2017 -PC -0205
Mr. LaBounty:
In response to Notice of Deficiency (NOD -2017 -PC -0205) for Certificate of Coverage
NCG140424, we offer the following:
RC Construction acknowledges the deficiencies in compliance with NPDES General Permit
requirements. The portable nature of the batch plant and lack of consistency of production by the
batch plant over the past several years is a contributing factor to the non-compliance. Since 2014,
the batch plant has been demobilized and remobilized three times, and has not consistently been
in production for any significant length of time over that period.
However, to prevent these deficiencies from recurring, the compliance responsibility is being
transferred to our Paving Quality Control Department, as these personnel will maintain a
constant presence at the project site anytime the plant is producing concrete. Corrective action
for the specific issues listed in the Notice of Deficiency are listed below:
1. No documentation of annual employee training,for 2015 or 2016. As noted above, our
Paving QC Department will .take control of all permit compliance responsibilities. As part
of this responsibility, our Quality Control Manager will compile training criteria and
ensure that annual training is provided to all personnel working on the batch plant site.
The Quality Control Manager will also ensure that training is properly documented and
electronically filed for review by NC I DEQ or other interested agencies. This training will
be a part of the new -hire orientation package for all RC employees, and will also be
provided to all subcontractor employees as part of the site-specific orientation process.
For projects that overlap calendar years, annual refresher training will be provided to all
Family owned and operated since 1987
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employees in January of the calendar year. This annual refresher training will include
specifically the employees that regularly work around the batch plant, but also include
any personnel that are regularly at the batch plant site. All subcontractors that demobilize
from the site for an extended period of time will receive refresher training upon
remobilization.
As an immediate solution to bring the site into compliance for 2017, the Quality Control
Manager will be conducting training with all on-site management employees and batch
plant personnel associated with the Pope Army Airfield site by August 31, 2017.
Documentation of the training provided, as well as a listing of personnel receiving the
training will be provided to DEMLR, FRO no later than September 8, 2017.
2. Analytical Monitoring has not been conducted and recorded in accordance with
permit requirements. RC Construction has contacted Building & Earth Sciences, who is
contracted to perform construction materials testing for concrete pavements and regularly
,has qualified technicians on-site during production operations, to conduct quarterly
analytical monitoring as required by NPDES General Permit NCG140000. The batch
plant is currently scheduled to be remobilized and placed back into production in early
October, 2017. During this production period, and all quarterly periods of production
going forward, the Quality Control Manager will coordinate with, Building & Earth
Sciences to perform the required quarterly analytical monitoring. An analytical
monitoring report for 4Q, 2017 will be provided to DEMLR, FRO no later than January
15, 2018.
3. One final note concerning the name of the facility. The name on the Air Quality Permit
(No. 10260R03) for the facility has previously been revised to be R.C. Construction
Company/Pope Army Airfield. Changing of the name on the NPDES portion of the
permit was simply an oversight as it was assumed that both would be revised
accordingly. The Quality Control Manager will be submitting a Permit Name/Ownership
.Change Form for Certificate of Coverage NCG 140424 to revise the name of the facility,
as well as. change the responsible person to be himself.
If there are any questions regarding this response, please contact the undersigned at (662)
453-2424, or Mr. Mustafa Elias, Quality Control Manager, (melias(arcconst.net) at (512)
- 966-.2294.