——— FAY BLOCK = A D.R. ALLEN & SON, INC. COMPANIES CONCRETE SERVICE Vv POST OFFICE DRAWER 1867 FAYETTEVILLE, NC 28302 RECEIVED Mr. Mike Turner ~ Environmental Specialist JUN 28 2023 NC Department of Environmental Quality a Division of Air Quality Fayetteville Regional Office ea rAverTEMLLe REE 225 Green Street, Suite 714 Fayetteville, North Carolina 28301 June 26, 2023 son OFFICE Subject: RESPONSE TO 6/13/23 NOV (AIR PERMIT NO. 02357R17) FAY BLOCK COMPANY FAYETTEVILLE, (CUMBERLAND COUNTY) NORTH CAROLINA Dear Mr. Turner: 1am writing in response to the Notice of Violation (NOV) received from your office on June 20, 2023, regarding inadequate records and documentation of elements of our fugitive dust prevention plan under our air permit. We appreciate the opportunity to address this matter and are working to ensure our compliance with the particulate control requirements under our air permit First and foremost, we take environmental, health and safety (EHS) compliance seriously and strive to ‘maintain the highest standards at our facility. We understand the importance of maintaining accurate records and documentation, and we sincerely apologize for oversights that have led to the issuance of the NOV. To address the specific concerns raised in the NOV, we are in the process of conducting a comprehensive internal audit of our fugitive dust prevention plan records and personnel responsibil Our findings indicate that while there were indeed certain gaps in the documentation due to recent employee staffing turnover in our EHS department, I'm confident that many activities were performed on schedule, Our HR/EHS Manager departed in May 2023. While we have since hired an HR Manager, Shawna Noonan, we are still actively seeking a replacement for the EHS Manager role to implement corrective measures to ensure ongoing compliance and record accuracy. (Please note that Scott Mosher and Durwood Hall have production responsibilities and are not involved in fugitive dust control activities, which is why they were unfamiliar with the air permit requirements during your inspection.) ies. We have located the template recordkeeping forms to maintain our compliance (see attached). Outlined below are the steps we are taking to rectify the process leadership and process execution issues, with an estimated implementation by July 15, 2023: * Assign a manager to oversee all environmental process compliance activities and recordkeeping requirements on the Ramsey St. site, * Develop a schedule for performing tasks associated with measuring, monitoring, and suppressing fugitive dust, and Page 1 of 5FAY BLOCK = LY D.R._ ALLEN & SON, INC. COMPANIES CONCRETE SERVICE POST OFFICE DRAWER 1867 FAYETTEVILLE, NC 28302 ————e Of ‘+ Update the recordkeeping forms as needed and maintain a central logbook to validate compliance. Revised Documentation Procedures: We have revised our internal procedures to ensure that all necessary records and documentation pertaining to our fugitive dust prevention plan are promptly and accurately recorded, This includes implementing a standardized format for record-keeping, specifying responsible personnel for documentation tasks, and conducting regular reviews to verify compliance. Employee Training and Awareness: We will conduct training sessions with our employees to reinforce the importance of accurate record-keeping and documentation. Our staff will be educated on the relevant regulations and guidelines, emphasizing the need for improved attention to detail in ‘maintaining and updating records. Enhanced Monitoring and Auditing: We are in the process of implementing enhanced monitoring and auditing processes to ensure ongoing compliance with our fugitive dust prevention plan. Regular inspections and internal audits will be conducted to verify the effectiveness of our measures, identify any potential deficiencies, and address them proactively. Documentation Retention: We are reviewing our document retention policy with regard to the fugitive dust plan and updating it to comply with the air permit requirements and applicable regulations. We are committed to maintaining records for the required duration and will implement a more robust system to organize and store documents for future reference and review. We are confident that these measures will prevent any future discrepancies in our records and documentation related to our fugitive dust prevention plan. Furthermore, we are open to collaborating with the Division of Air Quality to provide any additional information or participate in any further discussions to resolve this matter completely. Considering our immediate actions to address the issues raised in the NOV, we kindly request that you reconsider the severity of the violation and consider it as a good-faith oversight rather than a deliberate disregard for compliance. We have always demonstrated compliance in the past and assure you that we are committed to continuous improvement and will make every effort to maintain strict adherence to the permit in the future. Page 2 of 5FAY BLOCK Y D.R. ALLEN & SON, INC. COMPANIES CONCRETE SERVICE i — 7 POST OFFICE DRAWER 1867 FAYETTEVILLE, NC 28302 —< Thank you for bringing our attention to this matter. We remain fully dedicated to environmental stewardship and look forward to working together to ensure compliance and protect our shared environment. If you should have questions during your review, please contact me at (910) 323-9198 at your convenience. Sincerely, FAY BLOCK MATERIALS Ae Joe Imhoff Operations Manager Attachments: * FIM 62-02-xx, Daily Aggregate Fugitive Dust Controls Form + FIM 62-02-x%, Dally Water Truck Log cc: R.Hill-RDHEC, 8, Allen, Jr. D. Hall, S. Moser — Fay Block Page 3 of 5Daily Aggregate Fugitive Dust Controls Moisture: W=Wet, M=Moist, D=Dry, ¥=Water(30 minutes) Mo/Yr: Wind Wind] Pile] Pie ie | Pile] Pile | Pile | Pile | Confirmed By: npr) | carecsom | 1 | 2 | 3 | « | 5s | 6 | 7 (atals) 10 1 12 13 14 15 16 Fotm: FM 62-020, Daly Fuglive Dust Controls, ‘ate Printed: 6/26/2023,. oa Daily Aggregate Fugitive Dust Controls Site: Maistre: W=Wel, M=Moist, D=Dry, V=Water20minues)__ Mo/Yr: emer —Wind | Pie] Pile] Pre | Pie] Pie] Pile] Pile] Confirmed B= Day| time | cea.r) | mpm | (recto | 4 | 2 | 3 | « | 5 | 6 | 7 as) 17 18 19 20 21 22 23 25 26 27 28 29 30 31 Form: FM 62-020, Daly Fughve Dust Controls. Date Printed: 6/26/2023,Site: Daily Water Truck Log Mo/Yr: Tine (started) Tine (nds) Weather (Raid) Comments: | confirmed By: | (as) 10 11 12 13 14 15 16 Foc: FM 62:02-x, Dally Fugltive Dust Controls, Date Printed 6/26/2023,Site: Day MolYr: Daily Water Truck Log Time (stares) Time (nae) Weather (Rainy) Comments ‘Confirmed By tas) 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Form: FM 62-02, Dally Fuglive Dust Controls Date Printed: 6/26/2023,