NCG140138_COMPLETE FILE - HISTORICAL_20110914

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/v u& l Llo J
DOC TYPE
RI HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ J fi l l D 0) C
YYYYMMDD

North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director
Secretary
September 14, 2011
Mr. Sam Cannady
Greystone Concrete Products, Inc.
2100 North Gamett Street
Henderson, NC 27537
Subject: Technical Assistance Site Visit
NPDES Stormwater General Permit NCG140138
Greystone Concrete Products, Inc.
Vance County
Dear Mr. Cannady:
On August 17, 2011, 1, Dave Parnell of the Raleigh Regional Office and Ken Pickle of the
Stormwater Permitting Unit, of the Division of Water Quality (DWQ), performed a
technical assistance site visit at the referenced facility. Your assistance was helpful and
appreciated, as was that of Michael Walker of El. This site visit was conducted to assist you
in meeting new requirements of your NPDES stormwater general permit referenced above.
The following observations were noted during the Division of Water Quality inspection:
SITE DESCRIPTION
This facility is a manufacturer of concrete products and a supplier of ready mix concrete.
Manufacturing operations were observed during the tour of the facility. "There are two
stormwater discharge outfalls (SDO) at the facility, which collects stormwater from the site.
The two SDO discharge to an unnamed tributary to Sandy Creek, a C NSW+ classified
waters, in the Roanoke River Basin. SDO # 1 is located on the southeastern side of the
property. Stormwater co -mingles with wastewater produced by concrete truck washing. A
series of settling ponds treat the now prior to discharging at SDO #I. A pH treatment system
is in place in the last of the ponds. SDO 42 is located on the southwestern side of the
property and actually lies off of your site in the railroad right of way. The flow to SDO #2 is
produced by stormwater from a majority of the site in addition to wastewater produced by
blower blowdown and kiln water. The process wastewater is permitted under NI'DES
NCG500312.
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone]
Internet: w nc vaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
None
rth Carolina
— Xaturally
Customer Service
877-623-6748

Greystone Concrete Products'.'Ina"" i
Technical Assistance Site Visit
Page 2
POTENTIAL SOLUTIONS
I commend Mr. Cannady for being proactive in addressing the facility's potential permit violations
and contacting DWQ. Our site visit was a response to his concerns in meeting the requirements of
Stormwater Permit NCG140138. A single TSS value of 1540 mg/L, in a preliminary analytical
monitoring sample, confirms that the treatment system that is currently in place will not adequately
treat stormwater flowing to SDO #2. To properly treat the stormwater flowing to SDO #2, we at the
Raleigh Regional Office of DWQ, recommend that you ask your engineer to design a stormwater
treatment system on your property, replacing the small pond which flows to the current SDO#2.
This new system must have adequate capacity to allow settling of solids from your stormwater,
before flowing from your site. A pre -settling basin or a forebay, in addition to a treatment pond(s),
are possibilities and will aid maintenance. A condition of your permit is that the division be notified
of any changes to your treatment system.
Section E, 3 reads:
The permittee shall give notice to the Director as soon as possible of any planned physical alterations
or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature orincreasethe quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to effluent
limitations in the permit, nor to notification requirements under 40 CFR Part 122.42 (a) (1).
Accordingly, please notify us of your planned changes. Again, thank you for your attention to your
permit requirements and letting us know of your concerns. Please let us know how we can further
assist you. If you have any questions regarding this correspondence, please contact me at: (919) 791-
4200 or email: david.narnellOncdenr gov.
Sincerely,
Dave Parnell
Environmental Specialist'
Surface Water Protection Section
Cc RRO/SWP files
DWQ Stormwater Permitting Unit
Mr. Michael Walker, PE
El
2101 Gateway Centre Blvd., Suite 200
Morrisville, NC 27560

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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 14, 2010
CERTIFIED MAIL 70081300 00001130 0965
RETURN RECEIPT REQUESTED
Mr. Sam Cannady
Greystone Concrete Products
2100 North Garnett Street
Henderson, NC 27537
Subject: NOTICE OF VIOLATION
NOV-2010-PC-1029
NPDES Permit NCG500312 &
NPDES Permit NCG 140138
Greystone Concrete Products
Vance County
Dear Mr. Cannady:
On September 9, 2010, a compliance evaluation inspection (CEI) of your concrete products production
facility, was performed by Dave Parnell of the Division of Water Quality (DWQ) Raleigh Regional Office.
The CEI encompassed both the stormwater and wastewater permit requirements. Your assistance was
appreciated and was helpful.
I. NPDES NCG 500312 Wastewater Permit Inspection:
The current certificate of coverage became effective August 1, 2007. The facility is authorized
to discharge boiler blowdown and condensate produced by the production of concrete block.
2. There is a second wastewater stream created by the pH treatment (truck washing) system, which
is covered under the NCG140000 Stormwater / Process Wastewater permit. This will be
addressed under the Stormwater/Process Wastewater permit inspection below.
3. The inspection began in the plant office where a review of permits and records were Conducted.
The NCG500312 permit was available. Discharge Monitoring Reports were not available for
review for compliance with permit limits and monitoring requirements. Chain of custody .
records were not available, as you reported that there had been no analytical monitoring since
2006. Failure to conduct this sampling is a violation of your permit and may result in a Civi•I
Penalty Assessment. If, in the case there is a shutdown of production resulting in no wastewater
North Carolina Division or Water Quality 1628 Mail service Center Raleigh, NC 27699-1628 Phone [phone] Customer Service One'
Internet: e�w.ncvvateraualit�gy oreore Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone] No hCarolina
nlurnU�
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Greystone Concrete Products ' Page 2 of 3
stream, enter "no flow' on the DMR for that sampling period. Please begin sampling as
required by your permit.
4. Currently there is a co -mingling of stormwater and boiler blowdown /condensate wastewater
before the combined flows enter the settling pond which discharges to Stormwater Discharge
Outfall (SDO) # 2 at the southwest corner of the site. As we discussed, please create and
begin sampling at either a discharge pipe or the discharge weir (of the settling pond) for
the waste water discharge monitoring point.
II. NPDES NCG140138 Stormwater/Process Wastewater Permit Inspection:
1. The general permit expired on July 31, 2009 and has been extended until 2011.
2. Secondary containment is required at this facility and was inspected during the site visit and
found to be in compliance.
3. The Stormwater Pollution Prevention Plan (SP3) was reviewed during the inspection. Please
address the following deficiencies:
A list of significant spills for the last three years is required to be within the plan.
Annual employee training is required and must be documented within the SP3.
The SP3 is required to be reviewed and updated annually, (include the updating of the list of
responsible parties).
The pH treatement system was observed during the inspection and appeared to be functioning.
At the time of the inspection, there was no discharge from the series of settling basins used in
the truck washing operation. During the CEI, you reported that there has been no Analytical
Monitoring Reporting conducted since 2006. This is a permit violation and may result in a Civil
Penalty Assessment. You must begin sampling as required by your permit, including the
sampling of the vehicle maintenance area as well as the truck washout treatment process
water discharge during representative rainfall events.
5. As mentioned in 1 (4) above, there is a co -mingling of stormwater and boiler blowdown
/condensate wastewater before the combined flows enter the settling pond which discharges to
Stormwater Discharge Outfall (SDO) # 2. Please create and begin sampling at either a
discharge pipe or the discharge weir (of the settling pond) to represent the SDO 42.
As we discussed during the inspection, your facility is in a complex situation of adhering to two permits,
both of which require sampling of process wastewater. The Raleigh Regional Office of DWQ is of the
opinion that your facility shall continue to be required to adhere to the requirements of the two NPDES
general permits.

Greystone Concrete Products
Page 3 of 3
Greystone Concrete Products is considered to be non -compliant with permit conditions of the NPDES
NCG500312 and the NPDES NCG140138 permits. Please provide a written response to this letter,
including a schedule with dates for completion, within 30 days of its receipt. Address the facility's
compliance efforts with respect to all of the'bold items noted above. Please be advised, that the
continuation of violations is a concern to DWQ and the assessment of civil penalties may be necessary. If
you have any questions regarding the attached report or any of the findings, please contact Dave Parnell at:
[phone] (or email: david.pamellna ncdenr.eov).
S//lli ly,
U/
Danny Smith
Regional Supervisor
Surface Water Protection Section
cc: WQ Central Files
Wastewater Permitting Unit
Stormwater Permitting Unit

Permit: NCG140138
SOC:
County: Vance
Region: Raleigh
Compliance Inspection Report
Effective: 08/01/09 Expiration: 06/30/11 Owner: Greystone Concrete Products Inc
Effective: Expiration: Facility: Greystone Concrete Products
2100 N Garnett St
Contact Person: Samuel H Cannady
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Inspection Date: 09/0812010 Entry Time: 10:00 AM
Primary Inspector: David R Parnell
Secondary Inspector(s):
Henderson NC 27536
Phone:[phone]
Certification:
Exit Time: 12:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Ready Mix Concrete Stormwater/wastewater Discharge
COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Storm water
(See attachment summary)
Page:1

Permit: NCG140138 Owner - Facility: Greystone Concrete Products Inc
Inspection Date: 0 08I2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page:2

Permit: NCG140138 Owner - Facility: Greystone Concrete Products Inc
Inspection Date: 09/08/2010 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?
■
❑
❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
Cl
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# 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?
❑
■
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
❑
# Is the Plan reviewed and updated annually?
❑
■
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: No spills reported verbally, but should be included in an updated SPPP.
No record of employee
training in 2009, asked to fax to DWQ if record is located. SPPP
is not updated annually.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
❑
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
❑
■
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
■
❑
❑
Comment: No sample results for the last year of permit year - 2009, as required.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
❑
❑
❑
■
# Were all outfalls observed during the inspection?
■
❑
130
# If the facility has representative outfall status, is it properly documented by the Division?
Cl
❑
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
❑
❑
❑
Page:3

Permit: NCG140138 Owner - Facility: Greystone Concrete Products Inc
Inspection Date: 09/08/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: No permit on hand -prior permit has been extended to 2011.
Page:4

■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailplece,
or on the front If space permits.
1. Article Addressed to:
MR. SAM CANNADY
GREYSTONE CONCRETE PRODUCTS
2100 NORTH GARNETT STREET
HENDERSON NC 27537
NOV-2010-PC-1029. NCG500312-NCG14013e
GREYSTONE CONCRETE PRODUCTSMANCE CO.
10/14/ 10.MAILE D.10/18/10.SW P. PARNELL
A.
X 0 Agent
❑ Addressee
B. eceived by ( Printed 'ND/ C. Date of Delivery
�b-lQ-a010
D. Is delivery address different frc4n Rem 17 0 Yes
If YES, enter delivery address below: ❑ No
3. Service Type
Lxb—Certmed Mall
❑ Express Mall
❑ Registered
libBWum Receipt for Merchandise
❑ Insured Mail
❑ C.O.D.
4. Restricted Delivery/ (Extra Feel ❑ Yes
2. Article Number 7008 1300 0000 1130 0965
(trarrs/er rrom servke IebeQ
7 - E�arrarrr L
7 O F F®®
n
a Postage $
a
7 Certified Fee
POSMIark
7 Return Receipt Fee
7 (Erdomarnern Required) Hem
7
Restricted Delivery Fee
7 (Endorsement Required)
7
Tou
MR. SAM CANNADY
R
GREYSTONE CONCRETE PRODUCTS
Sent.
2100 NORTH GARNETT STREET
7
HENDERSON NC 27537
3
NOV-2010-PC.1029.NCG500312-NCG740136�-----------
Sirae
or PG
GREYSTONE CONCRETE PRODUCTS VANCE CO.
..----
10/ 14/1 O.MAILED. 10/18/10.SWP.PARNELL ...........
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t02595O2-M-15G0

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Wafer Qualify
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 8, 2010
Mr. Sam Cannadv
Greystone Concrete Products
P.O. "ox 630
Henderson, NC 27536
Subject: General Permit No. NCG140000 Continued Permit
Coverage for Greystone Concrete Products
COC NCG140138
Dear Mr. Cannady:
I spoke to you today regarding your coverage under NCG1400000. I checked in our system and your
facility is currently up to date on your billing and has current permit coverage.
Last year we had numerous stormwater general permits to renew. Consequently we pushed back the
renewal and revision of NCG1400000 until July 1, 2011. We did not mail out new Certificates of
Coverage to permittees or new General Permits as the current general permit dated August 1, 2009-
June 30, 2011 has the same coverage as the previous permit. Therefore, your site will not have a new
copy of your COC and General Permit until you apply and receive a new General Permit in 2011.
If you wish you download a new copy of your General Permit you may from our website:
http://portal.ncdenr.org/web/wq/ws/su/npdessw. If you have any further questions, please contact
me at telephone number [phone].
Sincerely,
Jennifer ]one
Environmental Engineer
cc: Raleigh Regional Office, Dave Parnell
Stormwater Permitting Unit Files
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location, 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 91M07-63001 FAX: [phone] Customer Service: 1-877-623-6748
Intemef,w .ncwaterqualiry.org
One
NorthCarolina
Natur-ally
An Equal Opportunity, 1 Affirmative Action Employer

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Permit: NCG140138
SOC:
County: Vance
Region: Raleigh
Compliance Inspection Report
Effective:08/01/09 Expiration: 06/30/11
Effective: Expiration:
Contact Person: Samuel H Cannady
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Inspection Date: 08/1712011 Entry Time: 10:00 AM
Primary Inspector: David R Parnell
Secondary Inspector(s):
Certification:
Owner: Greystone Concrete Products Inc
Facility: Greystone Concrete Products
2100 N Garnett St
Henderson NC 27536
Phone:[phone]
Exit Time: 12:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Technical Assistance
Permit Inspection Type: Ready Mix Concrete Stormwater/Wastewater Discharge
COC
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
■ Storm water
(See attachment summary)
Page: 1

I
Permit: NCG140138 Owner - Facility: Greystone Concrete Products Inc
Inspection Date: 08/17/2011 Inspection Type: Technical Assistance Reason for Visit: Routine
Inspection Summary:
Ken Pickle of SPU and Dave Parnell of RRO/SWP met with Sam Canandy of Greystone Concrete and Michael Walker of
El (Consultant) [phone [phone]] at the company site. Reviewed the processes of the plant and tried to figure out if the
facility is properly permitted under NPDES stormwater and NPDES wastewater requirements. The facility has two
stormwater outfalls. #1 has Wastewater from truck drum wash out co -mingled with stormwater that has a pile of concrete
debris removed from the bottom of the ponds during maintenance. The pH adjuster for the last pond in the series was
viewed. There was discussion on how Mr. Cannady sets the controls and Ken and I agreed that he was setting it in a way
to be most effective in the settling process. Discussion also envolved the location of the SDO and where to sample. The
current sample location apparently does not include the flow from the last pond in the series, just the stormwater coming
from the pile and the vegetated area. #2 has the stormwater flow from most of the site, picking up a huge amount of
suspended solids from dust and crushed stone by heavy trucks. Also going to this SDO is boiler blowdown (WWpermit)
and the kiln drippings (WWpermit). They sampled independently for the WW permit. The current pond is located in the
RR r/w and is way undersized to accomodate the flow and amount of suspended solids it receives. Mr. Cannady is being
proactive in trying to figure out how to meet permit requirements prior to the sample period goes into effect. Ken Pickle
will respond back to me after he determines if the facility is properly permitted.
Page:2

Mr. Sam Cannady
Greystone Concrete Products
P.O. Box 680
Henderson, North Carolina 27536
Dear Mr. Cannady:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleco H. Sullins, Director
Division of Water Quality
August 28, 2007 n (� (' n °�h
I�r1 F' l
AUG 3 0 2007
�DENR RALEIGH REG:��.L OfrICE;
Subject: Authorization to Construct Request
Greystone Concrete Products
NPDES General Permif NCG140138
Application Return (Return #1151)
Vance County
On August 20, 2007, the Division of Water Quality received your request for an
Authorization to Construct (ATC) a series of settling ponds and chemical feed pH -adjustment
system. After preliminary review, the Stormwater Permitting Unit (SPU) has determined the
submitted materials are insufficient for us to continue processing this ATC request. A summary
is included below to help you address deficiencies so that you can resubmit a complete ATC
request package.
We are also enclosing a copy of the Notice of Intent (NOI) application form as guidance
because it explains ATC requirements (please see highlighted sections). You do not need to fill
out this form because the facility is already covered under NCG140000. Please note that North
Carolina General Statutes require an Authorization to Construct wastewater treatment works
(G.S. §143-215.1), and that you must obtain approval for proposed treatment facilities
before construction begins. We understand that you are responding to a Notice of Violation
(NOV No. 2007-PC-0195) and are striving to comply with the conditions of your discharge
permit as soon as possible. Addressing the following items will expedite review of this project:
Plans and Specifications: These must be prepared either by a Professional Engineer or
employee internal to the company that is qualified to perform such work in accordance
with G.S. 89C-25(7). The plans submitted were not signed and sealed by a P.E.; the
submittal appears to be a site plan originally prepared by a Land Surveyor that was
modified to show proposed wastewater treatment structures. Also, no specifications for
the proposed washout and settling basins were provided (only some information about
dimensions were outlined in the cover letter).
Nr"o��nnCarolina
walurall!l
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterguality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Face [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycledll 0% Post Consumer Paper

A •,

t . Mr. Sam Cannady
Greystone Concrete Products
Authorization to Construct (ATC) Request Return
August 28, 2007
Design Calculations and Basis for Washout and Settling Basins
a. You must provide calculations to demonstrate that retention time and settling
capacity will be sufficient to meet effluent limits for TSS and Settleable Solids in
the NCG140000 permit. For example, these could include Stoke's Law
calculations and assumptions.
b. The letter asserted the washout basin will retain water "generally between 2 to 3
feet." Please describe daily water throughput and outline the basis (number of
trucks routinely washed out, amount of water per truck, etc.)
c. Include specific dimensions for each basin,.volume calculations, and clarify
whether the washout basin will receive any runoff from areas of the site.
d. Provide details about the size stone which the treatment system is designed to
contain during operating conditions (for example, the 10-year, 24-hour storm
depth). Include the amount of freeboard that can be maintained in these basins
during the design stone event.
e. Explain how often solids will be cleaned out of the basins and any other
maintenance that will affect the treatment capacity of the system.
The ATC request package is being returned to you with this letter. The return of this
application does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality or permits required by the Division of Land Resources, Coastal
Area Management Act or any other federal or local governmental permit or approval that may be
required.
If you have any questions concerning this matter, please contact Bethany Georgoulias at
[phone], extension 529.
Sincerely,
for Coleen Sullins
enclosure
cc: Raleigh Regional Office
Michael L. Walker, P.E./ El Inc./ 2101 Gateway Centre Blvd., Suite 200/ Morrisville, NC
27560
Central Files
Stormwater Permitting Unit Files

May 30, 2007
Charles Wakild, P.E.
Surface Water Quality Supervisor
Raleigh Regional Office
NCDENR — Water Quality Section
1628 Mail Service Center
Raleigh, NC 27699-1628
RE: NOV 2007-PC-0195
plI/Solids Corrective Action Plan
Greystone Concrete Products
Vance County
Permit Nos NCG150138 & NCG500312
Dear Mr. Wakild:
AEI
r.
This letter is submitted on behalf of Greystone Concrete Products and is in response to your
March 28, 2007 letter and a follow-up to subsequent conversations. Although your letter
documented the findings of your site inspection on March 21, Item Number 1, associated with
the quality of the discharge from the drum wash area was most significant. As requested, this
letter serves as the Corrective Action Plan associated with remedying that discharge issue.
Subsequent to your letter and in an effort to develop a solution to the elevated pH and solids in
the drum wash discharge, Greystone as completed the following:
Inspected the wash water management facility at another concrete batch plant. Greystone
personnel inspected the facilities and equipment associated with the management of
washout water at a Readi-Mix Concrete plant in north Raleigh on May 2. The inspection
of the facility and discussion with the plant manager was extremely helpful in
understanding how best to manage the drum wash water at the Greystone facility.
2. Developed a sketch of the washout basins. Based on flow rates anticipated at the
Greystone facility, a sketch of the three -chamber basin for managing washout water was
developed along with a site location sketch (see attached).
3. Contacted Fortrans, Inc. and secured a bid for the chemical feed and monitoring
equipment associated with the remedy. The equipment has been ordered.
Greystone plans to complete development of the sediment and neutralization chambers within
the next three weeks. Once the chambers are dug they will be used immediately for drum
washout operations, thereby improving discharge quality. The pH neutralization equipment is
expected to be delivered and installed within four weeks. The neutralization equipment will be
commissioned immediately and the system balanced as quickly as possible to meet the
requirements of your letter.
2101 Gateway Centre Boulevard • Suite 200 • Morrisville. NC 27560 • Tel: [phone] • Fax: [phone]

Mr. Charles Wakild, P.E.
Raleigh Regional Office
NCDENR — Water Quality Section
May 30, 2007
Page 2
Thank you for your attention and assistance in this matter. We are committed to remedying this
particular issue, as is evident by the corrective actions Greystone has already initiated.
If DWQ has any questions or concerns about our approach, please contact us at your earliest
convenience. Otherwise we will proceed as described. Thank you for your attention.
Sincerely,
EI, Inc.
Michael L. Walker, P.E.
Manager
Environmental & Engineering Services
MLW/
Attachments
Cc: Sam Cannady, Greystone Concrete
ENMO071004 File
2101 Gateway Centre Boulevard • Suite 200 • Morrisville, NC 27560 • Tel: [phone] • Fax: [phone]

GREYSTONE CONCRETE PRODUCTS, INC.
P.O. Box 680 • PHONE [phone] • FAx [phone]
JOHN F CANNADY, III, PRESIDENT
s� ERNESTINE C. CANNADY. VICE-PRES.
I�
JOHN F. CANNADY. IV. EXEC. VICE-PRES.
SAMUEL H. CANNADY. SEC.-TREAS.
HENDERSON, NORTH CAROLINA 27536
Mr. Charles Wakild, PE
Surface Water Quality Supervisor
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Mr. Wakild:
I:—
April 18, 2007
i7
Re: Notice of Violation 2007-PC-0195
Permit Nos: NCG 140138 & NCG500312
This letter is in reply to your correspondence of March 28, 2007 concerning the recent DWQ compliance
inspection of our facility. With reference to your Notice Of Violation and directive to submit a detailed
corrective plan within 30 days of receipt of your letter, I have taken the following steps toward compliance:
(1) I contacted our industry trade organization, The Carolinas Ready Mixed Concrete
Association, seeking assistance in locating ready mix concrete producers in my
area that have successfully installed high pH washout water control and remediation
systems. The Association supplied me with the names of several ready mix producers
in the Raleigh, NC area. One of these producers told me that he was well pleased
with a pH control manufactured and sold by Fortrans, Inc. of Wendell, NC.
(2) A few days later I met with a representative of Fortrans in my office and obtained
some specific information about their pH treatment system. Their system operates
by injecting carbon dioxide gas into a re -circulating stream of high pH water until the
correct pH level is reached. After an inspection of Greystone's mixer trucks washout
area, the Fortrans rep suggested that from his experience at other sites, I would likely
need to hire a certified engineer to re -design our washout area in order to successfully
integrate it with his system.
(3) 1 then contacted the environmental engineer who put together Greystone's storm water
and air pollution plans. He is with Environmental Investigations, Inc. in Durham, NC
and is very familiar with our site. He and I both agree that we should visit a ready
mix plant that has a Fortrans system installed and running. I again called the Raleigh
area ready mix producer to see if I could arrange a visit by myself and the engineer
so that we could observe the producer's Fortrans unit and ask about its operations
and effectiveness. The ready mix producer said that a visit would be fine with him

Page 2
April 18, 2007
but the persons who know the most about the pH control system would need a
couple of days to arrange their schedules to accommodate us. The producer then
asked that I call him Monday, April 23rd so that we could agree on a date and time
to meet at his facility.
The above narrative is a brief explanation of what I have been able to accomplish to date toward your thirty days
compliance schedule deadline. In order to begin the compliance process, I have had to contact a number of
persons at different times and dates, some of whom were not immediately available due to vacations or prior
business commitments. As you can readily see, this process has taken somewhat over two weeks of my allotted
thirty day deadline just for the pH control section of your notice of violation. Since the pH remediation is by far
the most complex and costly of the several violations listed in your letter, I feel that I must devote most of my
time addressing it first. However, this does not mean that I am ignoring the other violations you listed, only that
they must assume a somewhat secondary importance to what I see as my primary task. Although I did not
mention these other violations in this letter I have, in fact, made some headway in dealing with a number of
these items and will have them corrected in two or three months.
In a short time I have gained an appreciation of the time and effort needed to create a properly constructed waste
water pH control system. With this in mind I do not think thirty days is enough time to engineer and sumit a
corrective plan that will satisfy the DWQ technical review process. Therefore I am requesting that you grant an
additional sixty (60) days, beginning on May 1, 2007, in which to complete this task.
If you have any questions or comments, please do not hesitate to call me Monday through Friday at
[phone].
Sincerely,
SHC: sj
INC.

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PSI
� -
Sam Cannady
Greystone Concrete Products
2100 North Garnett Street
Henderson, NC 27537
Dear Mr. Cannady:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
March 28, 2007
Alan W. Klimek, P.E. Director
Colleen H. Sullins, Deputy Director
Division of Water Quality
�AL
Subject: Compliance Evaluation Inspection
Notice of Violation 2007-PC-0195
Greystone Concrete products
Vance County
Permit Nos.: NCG140138
NCG500312
On March 21, 2006, a compliance inspection of the subject facility was performed by Shannon
Langley and Ron Boone of the Division of Water Quality's (DWQ) Raleigh Regional Office.
Mr. Jim McKay of the DWQ Central Office accompanied regional staff during the inspection.
Your assistance was greatly appreciated and very helpful. A checklist for permit NCG140138 is
enclosed with this letter. The following observations were made.
The facility continues to experience elevated pH and solids values from the discharge
where the truck drum washout is located. These discharges are in violation of the subject
permit and must be addressed. After the inspection was conducted, a file review was
done. It was noted in our files that a Notice of Violation was issued to the facility dated
December 29, 2004 for violations of pH and Total suspended solids. Within 30 days of
your receipt of this letter you are directed to submit a detailed corrective action plan
including an implementation schedule leading to full and continuous compliance with
these parameters.
2. The oil changing station on site has numerous areas that need to be excavated and
disposed of properly. Runoff from the area flows directly into a small drainage ditch and
eventually to the holding pond on the lower end of your property. Pictures of the area
from the day of our inspection are attached. There was also a 55-gallon drum where old
filters were being burned. This is not an approved disposal method. Used oil was noted
in the drum along with old filters. Please submit a plan for modifications to this area that
will correct the noted violations.
3. An elevated 55-gallon drum was observed on the backside of the property near the boiler
building. You stated this is for fueling vehicles. It is highly recommended that this
fueling system be replaced.
4. The facility's SPPP was in good order and records are being kept as required.
Documentation of employee training is kept and the SPPP manual had all of the required
Raleigh Regional Office
Water Quality Section
1628 Mail Service Center
Raleigh, NC 27699-1628
A TUN.
ion
NCD W
phone [phone] Customer Service
facsimile [phone] 1-877-623-6748
One
NofhCarolina
a

Greystone Concrete
03/28/07
Page 2 of 3
components. We recommend noting when the manual is reviewed each year. This could
$;-'bZ'done'along with?the employee training.
5t--T-he-watersoftener at the facility discharges but is not permitted individually or covered
by the boiler blow down permit. We discussed this briefly during the inspection. By
copy of this letter the RRO is asking for guidance from our central office in addressing
this issue as it likely effects several facilities throughout the State. More information
about this may follow.
6. Sampling of the boiler blow down water is being conducted as required by the permit.
7. The facility uses a chemical to prevent scaling but does not use algaecides or biocides. A
copy of the MSDS sheet for this chemical was provided to us during the inspection.
8. Secondary containment is provided for the two above ground storage tanks.
9. The facility has its own pH testing equipment and sends other required samples to Tritest
for analysis. Records for these samples were reviewed and found to be.in good order.
While many of the requiremerits are being met, the continued discharge of high pH wastewater
and Total suspended solids require modifications in order to become compliant. A Notice of
Violation for these issues was issued in 2004. As stated above our office expects to receive a
plan for correcting those issues within 30 days of your receipt of this letter. The area where the
oil is changed must be re-evaluated in order to prevent runoff into the ditch and the existing oil
on the ground must be removed and disposed of properly. Please address this issue in your
response as well.
Please let us know if you have any questions or if we can be of assistance to you in any way.
You may reach our office at [phone].
Sincerely,
Charles Wakild, P.E.
Surface Water Quality Supervisor
Raleigh Regional Office
Cc: PRO files
Jim McKay — NPDES Unit
Central Files

Greystone Concrete
03/28/07
Page 3 of 3
Oil changing
station at
Greystone
concrete products
3/21/2007
Photo taken by
Shannon Langley

Readymix Concrete Stormwater Inspection Checklist
Type of Visit ®Compliance Inspection/Program Audit ❑Tech Assistance or Recon
Location: Garnett Street in Henderson
Facility Number NCG140138Date
People Interviewed, and Titles:
Time Inl0:00 am Time Out 12:15 pm
SPPP Documentation (Site Plan Part II (A)(1)
1. Copy of Certificate of Coverage ®Yes ❑No Copy of Permit ®Yes ❑No Requested but not required
2. General Location (USGS) Map shows plant ®Yes ❑No, lines of discharge Part II(A)(1)(a)
to water of State ®Yes ®No, Stream labeled ®Yes ❑No, Latitude and longitude ®Yes ❑No
Comments:
3. Narrative Description of Practices ®Yes [:]No Part II(A)(1)(b)
4. Site map ®Yes ❑No Shows flows & areas served with arrows and Part II(A)(I)(c)
% impervious surface ❑Yes []No, buildings ®Yes []No, process areas ®Yes []No,
disposal areas ❑Yes ❑No, drainage structures ®Yes ❑No, existing BMPs such as secondary containment
®Yes ❑No, list of potential pollutants ®Yes ❑No
Comments:
5. List of significant spills in last 3 years or certif if none []Yes ❑No Not checked Part II(A)(1)(d)
RRO called? ❑Yes ❑No
6. SW outfalls have been evaluated for process water ❑Yes ❑No Part II(A)(1)(e)
7. Feasibility of Changing Practices ❑Yes ❑No Part lI(A)(2)(a)
8. Secondary Containment ®Yes ❑No Schedule needed? ❑Yes ❑No Part II(A)(2)(b)
Records of Draining Containment, Observations Made []Yes ❑No
9. BMP Summary ®Yes ❑No Part II(A)(2)(e)
10. SPRP Plan ®Yes ❑No, Responsible personnel still employed here? ®Yes ❑No Part II(A)(3)
11. PM and Housekeeping Plan ®Yes []No Record of Inspections? ❑Yes [-]No Part II(A)(4)
12. Employee training ®Yes ❑No — for everybody Dyes ❑No Part II(A)(5)
13. Responsible parties, chain of command page ®Yes ❑No Part II(A)(6)
14. Plan updated/reviewed annually Dyes ❑No Staff Indicated it is but not documented Part II(A)(7)
15. Stormwater Facility Inspection Program ®Yes ❑No Part II(A)(8)
16. This Plan Has Been Implemented (documents in manual, Part 11(A)(9)
employees show awareness ®Yes []No Comments:
Sampling and Analytical Data Part II(C)
All Stormwater and Process Water is Recycled (IIC(3)) ❑Yes ®No
Rain Gauge on site (not required) ®Yes []No
Record of an overflow ®Yes ❑No Details
If not all recycled, what is allowed to discharge? Vehicle Cleaning (IIC2) ❑ Recycle overflow (IIC3
above) ❑ Wetting of Aggregate (IIC4)® Mixing drum cleanout (IIC5) ❑ Vehicle Maintenance ❑
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.

For the topics checked in last question, Analytical data present ®Yes ❑No, Compliant? ❑Yes ®No
Details:High pH and solids
Total precip []Yes []No, Storm duration ❑Yes ❑No, Total flow Est. ❑Yes ❑No,Field pH ❑Yes ❑No,
Chain of custody ®Yes ❑No
Qualitative Monitoring performed semiannually ®Yes ❑No Part II(F)
Stormwater not combined with process wastewater — general runoff PartII(C)(1)
Analytical data ®Yes ❑No, Chain of Custody ®Yes ❑No, Qualitative Monitoring performed
semiannually (Section F) ®Yes ❑No,
If using cutoff policy, how many sample rounds
Cutoff Concentrations met ❑Yes []No Ever have a Bypass? ❑Yes ❑No (III (C)(4)a1&2)
Notification given? ❑Yes ❑No I
Outdoor Inspection
I located all discharge points ®Yes ❑No No. of areas served
Sample points appropriate ®Yes ❑No
Location if different from discharge point
Housekeenine• Trash []Yes []No Dust ❑Yes ❑No
Take pH []Yes ®No Value(s)
Take photos ®Yes []No
Containment Area satisfactory ®Yes ❑No, Loose drums ❑Yes ®No, Locked drain ®Yes ❑No
Concrete disposal pile comments
Inspection Summary Comments
High pH and solids in discharge. Oil changing area needs to be worked on. Drains to ditch. A lot of
oil on the ground. Took pictures.
Recommendations:
Requirements:
Letter is to go to:
Name
Title
Address
Helpful Information at http://h2o.enr.state.nc us/su/Manu tIs Factsheets htm
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.

RE: Greystone Concrete pH adjustment equipment and response to NOV
Subject: RE: Greystone Concrete pH adjustment equipment and response to NOV
From: "Mike Walker" <[e-mail]>
Date: Fri, 8 Jun 2007 14:30:28 -0400
To: "Shannon Langley" <shannon.langley@ncmail. net>, <[e-mail]>
I have contacted Fortrans for specifics and cut sheets on the unit being
supplied to Greystone. I will put together something and submit it
within the next couple of weeks.
Thank you for your attention on this issue.
Michael L. walker, P.E.
Manager, Environmental & Engineering Services
EI, Inc.
2101 Gateway Centre Boulevard, Suite 200
Morrisville, NC 27560
919-657-7500 ext 245
Cell 919-280-9889
Fax [phone]
"Your One and Only Call for Quality Loss Prevention Services"
Visit us at: www.eil.com
-----Original Message -----
From: Shannon Langley [mailto:[e-mail]]
Sent: Tuesday, June 05, 2007 10:05 AM
To: Mike Walker; [e-mail]
Subject: Greystone Concrete pH adjustment equipment and response to NOV
Mr. Walker,
i received your letter in response to the Notice of Violation (NOV) our
office sent to Greystone Concrete in Vance County. I appreciate your
assistance with the development of a corrective action plan for the
facility. The installation of the Fortrans unit to adjust pH, requires
an Authorization to Construct (ATC) from our central office. Our
central office staff tell me they have seen several of the Fortrans
systems installed and have confidence in the integrity of the equipment
itself, but, as with all equipment, it must be installed as part of a
system, and that's why we require an ATC under the seal of a PE. The
PE's certification assures us that (s)he has considered all the relevant
conditions and that the design of the whole system will maintain pH
within permit limits.
The ATC application package should include AT LEAST:
*-a cover letter requesting an ATC with a proposed schedule, (there is
not an application form for this type of ATC)
-a cut sheet of the Fortrans equipment,
-a brief operations narrative,
- a stamped site plan and any detail sheets showing the particulars of
the installation, in sufficient detail to give us a complete picture of
the installation and the site, including at least: the route of the
power conduit to the equipment, that the equipment is located out of the
traffic patterns, and not likely to be damaged by vehicles, what the
beginning set point for pH control will be, how the whole treatment
system is configured so that we can see the discharge outlet and that
the water being discharged is indeed receiving pH control.*
I of 2 6/8/2007 3:09 PM

RE: Greystone Concrete pH adjustment equipment and response to NOV
L
If you will note in your cover letter that the installation is in
response to an NOV, then we'll try to process it expeditiously so
installation can occur. The package should be sent to the attention of
the "Storm water Permitting Unit" at 1617 Mail Service Center, Raleigh,
NC 27699-1617.
I am copying the facility (Sam Cannady) on this email as an FYI and also
giving them a call. Thanks you for your help. Let me know if you have
any questions.
(Mr.) Shannon Langley
2 of 2 6/8/2007 3:09 Pal

d
F WATF Michael F. Easley, Governor
Q 9 William G. Ross Jr., Secretary
\O' OG North Carolina Department of Environment and Natural Resources
pj r Alan W. Klimek, P.E. Director
Division of Water Quality
O ,<
April 28, 2003
CERTIFIED MAIL
RECEIPT REQUIRED
Mr. Samuel Cannady
Greystone Concrete Products, Inc.
2100 N. Garnette St.
Henderson, NC 27536
Subject: Notice of Violation
Notice of Recommendation for Enforcement
NPDES Stormwater Compliance Evaluation Inspection
Permit No. NCG 140138
Vance County
Dear Mr. Cannady:
On April 21, 2003 Mr. Myrl Nisely of the Raleigh Regional office of Division of Water Quality
met with you to make a compliance inspection of the Greystone Concrete Plant in Henderson.
Your help was greatly appreciated. Attached is an inspection checklist. Findings were as
follows:
The Stormwater Pollution Prevention Plan (SP3) had been professionally revised in January
2003 and contained all the required topics. However, as you readily admitted at the beginning of
the inspection, no action has been taken so far to carry out the program. Stormwater permits for
ready mix concrete plants have been in effect since 1994. The present version of the permit was
issued in 1999 and provided a two year grace period for programs details to be put into place.
Therefore, your manual should have already contained documentation for at least the years 2001
and 2002. The failure to carry out the program details below is the reason for this letter being a
NOV. Enforcement fines may also be imposed.
Secondary Containment Records of Draining Containments, Observations Made, Part II(A)(2)(b)
PM and Housekeeping Record of Inspections Part II(A)(4)
Employee Training Annually Part II(A)(5)
Stormwater Facility Inspection Program Part II(A)(8)
Sampling and Analytical Data Part II(C)
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile [phone] 1-877-623-6748

C
Greystone Concrete Page 2 of2
NCG140138 April, 2003
This office is considering recommending to the Director of the Division of Water Quality that
civil penalties be assessed against your company for these violations. NCGS 143-215.6 provides
that violations of 143-215.1 may incur civil penalties up to $25,000 per violation per day. Anv
response submitted to this office within 10 days of receipt of this letter will be considered when
making the recommendation
A system of checkdams and a vegetated channel appear likely to help reduce the impact of water
released from the drum wash pit. However, no evaluation of the engineered features for
handling stormwater at the facility was carried out. Mr. Nisely was unable to measure pH that
day when the meter failed to calibrate properly. In addition to annual sampling, all discharge
points need to be checked occasionally to be certain they meet the parameter limits in the permit.
The settling pond at the South end of the property should be maintained to drain well. It may
now reach a level high enough to force water back into the plant during a heavy rain. Please
contact the Railroad in an effort to gain improvements.
As suggested in the checklist, specific action steps need to be taken to provide a plan of attack.
These should include use of a calendar to establish inspections, contact with a commercial
laboratory to contract for tests to be run. They will supply bottles and give guidance on how
samples are to be preserved and shipped. Tip: some concrete plants place a chart of what is to be
done monthly, quarterly, semi-annually and annually under the front cover of their manual, then
fill in dates when the actions are accomplished.
By May 30. 2003, submit to the Raleigh Regional Office a plan for accomplishing the tasks
required by the permit.
Sincerely, V�,�,�
0 0 ! ° E I @Ar®
Kenneth Schuster, P.E.
Water Quality Regional Supervisor
xc: NPDES Compliance Unit
RRO WQ Files
Central Files