NCG050429_Inspection Report (City of WS)_20210408

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UstonVem
Field Operalioas
Stomnvater Division
Ciry aF Winsron-Snlcm
CO. Box 2511
Winston-Salem, NC 27102
CityLink 336.727.8000
March 3, 2021
Vance Vaughn
Safety Manager
Westrock Converting Company
5930 Grassy Creels Boulevard
Winston-Salem, NC 27105
Dear Mr. Vaugbn:
The Stormwater Division of the City of Winston-Salem would like to thank you for
your time and professional courtesy regarding the February 24, 2021 inspection of
Westrock Converting Company.
As per our discussion, a copy of the completed inspection form has been enclosed to
you. Part 5 of this report (Required Actions to be completed by Facility) contains
Annotations #1-5 that Westrock Converting Company must complete. Please provide
documentation that verifies Westrock Converting Company successfully completed
the corrective measures to me by June 4, 2021.
The Stormwater Division reserves the right to enter Westrock Converting Company
as often as necessary to determine compliance with the permit requirement of
NCG050429.
Thank you for your continued support of the City ofWinston-Salem's Stormwater
Program. If you have any questions, please feel free to contact me.
Sincerely,
Brandon ise, CESSWI
Stormwater Inspector
Office: [phone]
Cell: [phone]
E-Mail: [e-mail]
�� ��� �", City Council: Mayor Allen Joiner; Denise D. Adams, Mayor Pro Tempore, North Ward; Barbara Hanes Broke, Northeast Ward; Robert C. Clark,
West Ward; John C. Larson, South Ward; Jeff Macintosh, Northwest Ward; Kevin Mundy, Sonlhwesl Ward; Annette Scippio, East Ward;
Call 311 or 336-727-800D lames'Paylor, Jr., Sonlheasl Ward; Lee D. Gerrity, Cily Manager
[e-mail]

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INnslon6alem
Stormwater/Erosion Control Division
Industrial and Municipal Good Housekeeping Inspection Forin
General Information
A) Official Company Name: Westrock Converting Company
B) Physical Address: 5900-A Grassy Creek Boulevard, Winston-Salem, NC 27105
C) Telephone Number: 336-661-1700(0)
D) Mailing Address, if different from above address: 5930 Grassy Creek Boulevard,. Winston-Salem, NC
27105
E) Authorized contacts to represent entity in environmental regulatory issues:
Primary contact: Vance Vaughn
Title: Safety Manager
Contact number(s): 336-661-6716(o)
Email address: [e-mail]
Secondary contact: Daryl Bryant
Title: Maintenance Superintendent
Contact number(s): 336-661-7321(o), 336-578-3426(c)
Email address: [e-mail]
F) Standard Industrial Classification (SIC) Number ofbusiness/operation (if applicable): 265
G) NC Stormwater NPDES Permit Number (if applicable): NCG050429
Permit Category: Apparel, Printing, Leather, Rubber
ITj Any other control authority pennit(s) (e.g. air quality control, wastewater, hazardous waste) & number(s):
Air Quality —Forsyth County 00856
RCRA Small Quantity — NCR000012690
I) Brief description of facility activities that occur on -site: Facility makes dyes and plates that are used for
creation of displays for clients. Mass produced products are cut and printed in the 5930/5950 buildings.
Facility also assembles different types of displays per customer requirements.
I) Ultimate Receiving Waters: Mill Creek
TMDL stream ❑Yes ®No If Yes, What Pollutants:
Part 1-Stormwater Controls
1. Best Management Practices (BMPs)
a. List the controls (structural or non-structural) emnloved by the
E.g. Oil Water separators, cleaning schedules, structural BMP maintenance records
1. Trash is picked up on a Monday/Wednesday/Friday schedule
2. Industrial activity is performed indoors
3. Small stormwater pond at Outfall 4

b. Are the non-structural BMPs reasonable & appropriate for the facility? ®Yes ❑No
Facility showed no signs of potential pollutants when performing the inspection. Trash
was minimal to non-existent at the facility.
c. Are stormwater control measures (SCMa) installed correctly, maintained, and effective operating condition?
®Yes ❑ No ❑ N/A
Single pond at outfall 4 was in good shape with rip -rap around the outfall. A rip -rap ditch
is located on the backside of the 5950 building and was in good shape.
2. Provide a brief descripfion of other controls that manage/prevent/minimize stmrnwater runoff
(e.g., erosion and sediment controls, inlet protection/control at storm drains, diversion structures):
Regular cleaning is performed by on -site staff. Catch basins are regularly inspected in addition to
trash and leaf litter being removed as needed. Sediment build-up in the parking lot ditch is
removed as needed.
Part 2 —Stormwater Discharge Outfalls (SDOs)
1. Any evidence of discharge to receiving waters/MS4 from the SDOs? (e.g:: stormwater runoff, dry weather
discharge, co -mingling of process wastewater, trash, debris, on and grease): ❑Yes ®No
Outfalls showed no signs of potential pollutants at the time of the inspection. Debris and
as at the outfalls was minimal.
2) Do the stormwater outfalls on -site correspond with those listed on the site map in the Stormwater Pollution
Prevention Plan (SWPPP)? ®Yes ❑No
Comments:
10 outfalls are on site that match the facility's map. Outfalls 1 & 10 are non -point sheet
flow outfalls and it is recommended that the facility evaluate these outfalls for potential
removal or creation of a true outfall. Ensure for future sampling events Outfall 4 is
sampled from the discharge point of the stormwater pond outside of the security fence.

3) Summary of Stormwater Discharge Outfalls
SDO Identification
Potential Pollutants that
Physical Location
Latitude and
could be discharged
Longitude
if known
Outfall 1
TSS, OWGrease from
Southeast corner of 5900
N/A
Parkin Lot, Trash
building.
Outfall 2
TSS, OWGrease from
East side of 5930 building,
N/A
Parking Lot Trash
south end of parking area
Outfall 3
TSS, Oil/Grease, Diesel
East side of 5930 building,
N/A
Fuel, Trash
middle of parking area
Holding pond, on east side
Outfall 4
TSS
of facility between 5930 &
N/A
5950 buildings
Outfall 5
TSS
Northeast corner of 5950
buildingN/A
Outfall 6
TSS, Oil/Grease from
Northwest corner of
N/A
Parking Lot, Trash
facility
TSS, Oil/Grease from
Across the parking lot
Outfall 7
Parking Lot, Trash
form southwest corner of
N/A
5930 building
Corner of facility near
Outfall 8
TSS, Trash
Grassy Creek & Bethania
N/A
Station intersection
At roof drain discharge
Outfall 9
TSS, Dye
from dye/plate making
N/A
building
Outfall 10
TSS, Oil/Grease from
Western end of 4720
N/A
Parking Lot, Trash
building's loading docks

Part 3 - BMP: Inspection and maintenance program
Yes N/A No Notes
Is secondary containment provided for materials (including
X
Single diesel fuel tank
waste) or products stored outside in tanks and/or containers
with built in and external
(where applicable)?
secondary containment.
Are secondary containment free of accumulated water, debris,
X
Secondary in good shape.
cracks, holes, or evidence of leaks?
Does the facility maintain secondary containment drain logs?
X
Secondary is built in and
covered.
Do the drain logs confirm the presence of pollutants and other
X
pertinent information, such as signatory requirements, name of
secondary containment area, date, time, and if drainage is
connected to MS4 or receiving waters?
Are tanks and containers in good condition, closed, and
X
Diesel tank is labeled and
properly marked?
in good shape.
Are tanks, containers, and piping free of rust, pits,
X
Diesel tank showed no
deterioration, or evidence of leaks?
signs of deterioration.
Are tanks and containers protected from impacts from moving
X
vehicles and e ui ment? E.g. bollards and curbs
Any activities that have not been addressed or designed in
X
order to minimize exposure to runoff (e.g. herbicide
application)
In the case of a spill, does the municipal operation or industrial
X
Keith Huffs information
facility maintain and submit documentation to the City of WS
needs to be added to spill
on a spill release form?
documentation.
Any roof stacks that have the potential to release
X
Cyclones on rooftops
solids/particulate?
collect scrap before it is
then processedindoors
Are all hazardous materials properly labeled and stored to
X
prevent exposure to stormwater runoff?
Are solid waste containers in good condition and of sufficient
X
All waste containers are
size to contain all waste? If so, how is this determined?
covered and in good
shape.
Do the solid waste containers have covers and closed drain
X
plugs?
Are solid waste containers free of waste that requires special
X
handling/disposal? Are containers properly labeled to ensure
correct disposal means?
Are solid waste containers labeled "Prohibited - No Hazardous
X
Labeling needs to be
Waste, No Recyclable Materials, No Liquids?"
added to all waste
containers.
Are special containers provided for other types of waste? E.g.
X
liquid waste or hazardous waste
Does the facility utilize oil water separators? If yes, are the
X
inspection and maintenance records documented?
Are secondary containment drain valves maintained in the
X
Valve was closed and
closed position, unless the facility is draining the secondary
locked at the time of the
containment?
inspection.

Site Overview
Part 4 — Stormwater Pollution Prevention Plan (SWPP) Review
Yes No Notes
Is there a SWPPP? Is it up-to-date?
X
Updated 2/2021
Does SWPPP include a certification statement by the responsible
X
Signed by Gene Matthews
corporate officer?
(General Manager)
Does the general map depict the facility's location on a USGS
X
USGS map with receiving
quad map (or equivalent map) with receiving waters (or MS4)
waters will need to be
listed?
added to SWPPP
Identification of impaired waters or watershed (if applicable)?
X
No impaired waters.
Narrative Description of these Industrial/Operational Activities:
All narrative descriptions
Storage Practices
X
required are provided in
Unloading/Loading Activities
X
the SWPPP. Majority of
Outdoor Processes
X
activities are performed
Particulate Generating/Control Processes
X
indoors except for
Waste Disposal
X
loading/unloading.
Vehicle/Equipment Washing-
X
Does site map denote drainage items: flow direction, boundaries,
X
Map needs to be updated to
% impervious, and structures? Does the map also include SDOs,
include topography and %
industrial activity areas, and site topography?
impervious calculations.
A list of major spills that have occurred within the past three years
X
with corrective actions to prevent futurespills)?
A signed, annual certification that the facility has been tested for
X
Signed by Gene Matthews
non-stormwater discharges from the site?
(General Manager)
Comments:
SWPPP has been recently updated and has all the narrative aspects required.
Maps for the facility need to be added to the SWPPP and updated to ensure
they contain all required features. Narrative aspects of the SWPPP are
detailed and site specific per permit requirements.
In future
sampling events Outfall 4 needs to be noted
as the discharge
point
from the
stormwater pond, not from the grate inside
of the fence line.
Keith Huffs information needs to be added to the spill response section of
the SWPPP and SPCC.

Stormwater Management Strategy
Yes No Notes
Does SWPPP incorporate the nine baseline controls:
X
X
Feasibility Study (technical & economic review to minimize pollutant exposure)
Secondary Containment (table summary of tanks, stored materials, release records)
X
Single 250 gallon diesel fuel
tank outside
X
BMP Summary (listing of site structural/nonstructural practices)
PM & GH (inspection of material handling areas & regular cleaning schedules)
X
Facility Inspections (biannual inspections of facility and all stormwater systems,
X
Facility inspections are
were the inspections completed during separate parts of the year?)
completed monthly with
regular monitoring done
weekly
Employee Training (annual basis for staff who perform SPRP and GH functions)
X
Responsible Party (specific position(s)/person(s)-developing, implementing, &
X
General Manager, Safety
revising SWPPP)
Manager, and Maintenance
Amendment& Annual Update (of major spills, non-swflows, BMPs,sampling data)
Superintendent listed.
X
Does SWPPP contain completed routine inspection reports/records
X
regarding reportable implementation of the nine baseline controls
e.. SWPPP Implementation)?
Does the Spill Response Procedures (SPRP) document all spills and
X
releases? Does the entity properly dispose of contaminated materials
used in the clean up? Is the disposal of materials documented? Has a
contact person(s) and contact information been identified and
documented for each facility?

Analytical Monitoring (V not applicable, please notate)
Yes No Notes
Are samples collected within 30 minutes of the first discharge from
N/A — Not Required
a measurable rain event and at least 72 hours since the last storm
event?
Are sampling events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
N/A — Not Required
Is analytical monitoring complete (including schedule) for each
N/A — Not Required
SDO? (EXCEPTION: REPRESENTATIVE OUTFALL STATUS)
N/A — Analytical sampling
Any exceedances of pollutant parameters when compared against
not required per the
the permit benchmark values? If yes, have they documented their
NCG05 permit due to the
response to the Department of Environmental Quality?
facility not performing
vehicle maintenance on -site.
N/A — Not Required
Has the facility implemented appropriate, selected actions to
reduce pollutant concentrations, in response to benchmark
exceedances (if applicable)?
Qualitative Monitoring
Yes No Notes
Is qualitative monitoring being performed during measurable storm
X
Qualitative monitoring
events?
being completed at all
outfalls
Is qualitative monitoring complete (including schedule) for each
X
SDO?
Are monitoring events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
X
X
No potential pollutants
Any observable, excessive amounts of pollutant indicators in
were noted in monitoring
stormwater discharge at SDOs?
records.

Part 5 —Required Actions to be completed by Facility:
Items to be completed 3 months from receipt of this letter:
1) Cigarette butts built up around the catch basin up gradient of the temporary employee parking
need to be cleaned up. Signage needs to be put in place stating "No Cigarette Butts in the storm
drain". (See Photo 1)
2) A USGS map with the facility and receiving waters identified must be added to the S WPPP.
3) The site map in the S WPPP must be updated to show the topography of the site and percentage
of impervious surface for each outfall.
4) Signage must be added to the waste containers stating "Prohibited - No Hazardous Waste, No
Recyclable Materials, No Liquids"
5) Add Keith Huff's contact information to the spill reporting list. Keith's contact info is:
Keith Huff
Director of Field Operations
336-747-6962
[e-mail]
Entity Representatives) that participated in inspection: Vance Vaughn &Daryl Bryant
Title(s): Safety Manager & Maintenance Superintendent
Start of Inspection: 8:50am
Completion of Inspection: 11:OOam
Date: February 24, 2021
Signature of Inspector:
Title: Stormwater Inspector

Photo 1—Cigarette butts in and around the storm drain located up gradient of the temporary
employee parking.
Cigarette butts built up around the catch basin up gradient of the temporary employee parking
need to be cleaned up. Signage needs to be put in place stating "No Cigarette Butts in the
storm drain".