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NCG030474_COMPLETE FILE - HISTORICAL_20150304
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. I IVC& 0.304.q4 DOCTYPE I 9 HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE I ❑ !� d I 5 l�� D 4 YYYYMMDD March 4, 2015 Mrs. Christine.Maclaren Human Recourses Lyndon Steel Company LLC Nbfic Works 1947 Union Cross Rd Deparunimi Winston Salem, NG.271'07 Stormwater/Frnsion;and Mrs- M ' laren_ SO&D2enuewu Go"traI Program ryofWr o m The.Stormwater-Division of the City of Winston=Salem would like to thank - PO" Box 2511 vrr,�an-s :11c2�ios you for your time and,professibnalcourtesy regarding the 7uly's30, 20-14 GrAink3u (336.727.SMO) inspection of Lyndon Steel Company-LLC;- Fu •33G.748 173 w_ ivrnt�_T:mrctz�rr_nacr.rmr Lyndon Steel Company LLC has prdvided:documentation that verifi_es'the successful completion of;the correctivermeasures located in Part 4 — Required -Actions io he. co' ied"&-Facij{ry. At"ahis time,"Lyndon,Steel CorhpanyyLLC has no outstanding=inspection compliance•iteiris to complete. The Stormwater Division7reserves the riglit-to:enter.and inspect Lyndon Steel Corripany.LLC ds often as-necess4ry to determine coinpliance with permit-requirements:'of NCG03,0474'.., Thank.youfor your -continued-support and impleinentationof the City of Winston-Salem's Storrnwater•Program. If you haveany questions; please feel free'to:contact me at (336) 747-6964. Sincerely, ' - Ladonta "Jamal"Clark_ Stormwater Inspector PB6ne:7336 74.7.6964 Cell: 336:4:16.2403 Fax: 336.74831.73 1 asp Dom. Cuy Came3 14mr Alien Jaaex lriwa ti Biuk:. Minor Pro Tmiporc, Igor ssi Ward Denise D. AAl N-d R'udt Dan Bene. Swrhww R'irdi Aa6eR C_ C]iek. R'en Wad may LeigJie Sondr Wud: Waada L).win L MoncpiwrK E= Want: jams Tiy6 Jr.. Seddss %ud: Gq Ste: Lm D. Gamey P Storrnwater/Erosion Control Division Surface -Water -Re -inspection ciftyndon, -Steel Company LLC Part .l,-Re wired Actions ram the July 30, 20144nspechon� Successfully C©Opjetedl? Yes No- Notes 1) His.'Lym-do n- Steel Company LLC clehijed'up Oil the leak.at 'the'receiving bay and increased cleaning. frequericy:to-weekly,, ✓ as:per, ykur�, Good.Housekeeping Pro ram reguiremefits ? 2)Has Lyndon St6el Corfipin� LLC replaideidthe old dumo%er ✓ with new,durnpstem 3) Has Lyndon Steel Company LLC provide&and updated the . signed.,deMicatiori statement by thejMpo risiblecgro.orlite -cifficer,motheir-SM? 4) Has Lyndon Steel ComDany LLC added.ihe receiving waters. ontsener4l'thav and included that SWdirfi creek is not a TM.DL stream? A6,1a's. L' yndon -Steel Company, ILC, included -in=the, is,nqariiffi" aiied.sthekfi? _SPPP,tbAt!Swajhicreek ,5) Has'L`Yridon. Steel Corripahy -LLC- proVidid , A signed, annual ✓ certificaii6n.thai Lyndon SteelCornpanv'LUC: has: been tested .- V. , I- fb� nbri"st6fiy� nate"r" discharge's ',fro the'§iteand'included ifin 6),Has- Lymon Steel ComgihyLLC--..upd 41 Winston Salem,Ston-nwatc!_DIvIsion7, s cbntact:inforrftati6h.t6, L don:Steel Company"s.LLC Spill 'Notification List?. 7),.IfpsLyn on A 'St6il Ponlany LLC.-_ Odat.dd-and,resikfied the 0 Managenient,Appr,bval.Stateinent-iAd- G erti6ing eogificiers'- staternenijri;SPPP2; 18), HMLyndon Stedt Com-"P-'Wiy,-LLC--.Itipdated,hhd: . signed the- VII Spill Prevention and,Response rocedures SPPP? .9)'Has,;,f ym' o C._&ovid6d-IeM6l6Yee Ve training ralh 4iilxesp6nsd#odddures W�gteKentiye,m6i.nt-enane'!2,'funciie�.Ws�.bv.th.e:ducdate of this, iris pection ap . ackage? 1'0).,-Has'Lyndon'St . celCompany LLC updatedLand. signed the ✓ -R6"oiisil ii.Paity,sectioii'"o'f theSPPP? II)E6§1'yndon'Ste'el Company'-LLC V" monitonng:4ischa!gp,*characteristics--,requi.ted., includingCO er-aIiti'Ziric?- 12)_Ms *dOn LY Steel Comikhy LLC dete iffn- YnOo No sdNdnt inahiji6ment S;,�eLCdm . pakiy,L LC.- reqWr.es%a gimvenf Managemeni-Plan -plan.--i'STeq*ed JromNCDNER'9. 13) HaS'Lyndon.St&F.Compa:ny LLC de'h6ted`iheiph:ysical ✓ location,, „ojititiM',poIlLitahi§Ahat"c6uld'beldischhrk d,-an&the latitude and longitude of the Stohnwater Discharge Outfalls L and 2, in•SP,PP and on site -map? 14) Has Lyndon. Steel Company LLC provided an annual table summary of tanks, stored. materials, and release records for their secondary containment? 2 — Required Actions to -be 1. None. Lyndon Steel Company, LLC has successfully completed all Required Actians io be completed -by the Facility of the'3uly 30,.2014 inspection. Signature of Stormwater Inspector: v4� 441,, Title: StormwateF'Inspector 3 f, August 13, 2014 Mrs: Christine-Maclaren nape Human Recourses Lyndon Steel .Company LLC Sto,mwaw/Erouon-and 1947 Union Cross Rd sed; �►i,a control Winston-Salem, N.C. 2.7107 city ofvv;s�, PO. Bm 2511 \Y/u�oa'8aM Nc 27103 Dear Mrs. Maclaren: Grylink 311 1336.727.8� Far 33&7483173 The Stormwater bivision of theCity of Winston-Salem would like to thank you -for your time and -professional courtesy' regarding. the July 30, 2014 inspection of Lyndon Steel.;Company LLC... As per your'requ - t, a -co "' bf the e6mpleted-surface water inspection form has becwenclosed to you.-Part•4 of this report (Required Aclions,tohe completed by Facility).contains Aniiotatians A1414 that'Lyndon Steel Company's LLC must complete: Please'provide dociimentatioft that verif es Lyndorr'Stee' Company's LLC successfulxon'ipletion of the_corfective nigasures-to ine by November 13, 2014. The Stormwater Division reserves the -right to•enter and inspect Lyndon Steel Cornpany's LLC as.often as necessary to•determine compliance with permit requirements of NCG030474. Thank -you for -your continued support and.imptemeritation of the City of Winston- Salem-'s Stormwater Program. 1f you have my, questions,,please feel free to L contact me at (336) 747-6964. Sincerely, Ladonta Clark S t o rrnwater-Inspector Phone: 336.747.6964 Cell: 336416.2403 Fax:335 748.33'173` Offimmki, Caeadl: FSiyvi ADen'A&N V- i" H. Mi,k Mx,u Pro T.'q m' Wink D,,,6, D Adahm Nwh W,,* Da Hi, So A- Wards P, bm G 0.& Wm Ward: Md}l �t Soe[h Waal: Wind: Mera�d 1V'ottL..eai l¢.nL Dn4in L �'' Fm Wald:lima Ta,iot Jr., Sa`idi�a Wank City Mina�cr. Ler Q. Guvtr Cell 3 i T or 336-727-8000 F citylinic@eitydfws.org P it (w Stoirz iWr Lter/Erosion=Coritrol Division Surface Water Inspection for Indusirial `Siies- General Information A) Official;Cbmpany-Name: Lyndon Steel Company. LLC B) Physical Address: 1947 Union= Cross:Rd;,Wiris'ton=Salem3XC. 27107 C) Telephone"-Number:=0ffice.336=785-0848:'e3it 92lS' D) Mailirig.Addfess, if different froiii-ab6a !e address: .;E) Authorized.contacts_ to: repre sent.eompany in:environmental:regulatory, issues: Pritriary contact: Mr i. Clrnstioe:MarlaVen - Title.Muman. Recourses =Manager•, Contact-ntimberf s) ,Office :(336)-785-0848 tit. 218- Cell (336Y9724436 �tinail address:£cmaclarenG7 ndons'teeI com 'Secondary contact: David Reid Title:flan't Manager Contact numbers) :Office `336-785-0848 eat. 228•Cellphone:-336-399-2103 Email'addrest: Dreid@yndonsfeeLcom V) SIC Gode.Number-of business: Fabrieating'of-Metal,Products (SIC 34) -6) NC Stormwater:NPDES Permit -,Number: NCGO30474_ �Y Permit Category.: E{General} alsricating _of Meial Products: H) Any'other control authority Oerutis).iiau;quaityi onfiol, wasfevater,:liazaiiious'viwaste);&;riumber(s): 1), Air<quality. Perinit: 00834 I Mazard.Ous waste permit -NCR 00001.1072 "i)'Wriefdescripiion:of,industriai activities_;that occur -on -site: The fabrica(ion,of steel products',fhai.are.sold for vinhiarercial purposes. I) Ultimate Recervrng`Waters- � Swaim Creek TMDL,stream ElYes 1. Best Management-Prat€ices M, ;Part 1 - StorfnwaterControls A. List -the nonfstiuctufal coritrol5�eiiito °ed.b ;the,facilit : 1. Tsie,paint stornge'area=hasya shed:over.ti e.;prdduets ta-prevent st©frmi+ateir'Odu rtioa 2: The iriaintsnance sliied.is, covered ta5pro'tecttitems"suchaas gas_cans; weed;esters.11WAmower�s _and oilier maclitae& b. Are the..BMPs reasonable.& appropriate for -the -facility? ®Yes ONo Immediately eleawup oil at leak -the receiving bay and increase cleaving frequency to weekly, as per your Good. Housekeeping Program requirements. c. Are BMPs installed correctly, maintained, and .effectiv_e operating condition? ®Yes ONo Comments The Secondary tanks used for,,-gasoline/kerosene are properly maintained. 2: provide a brief description of -other controls that,manage/preventlminimize stormwater runoff (e.g., erosion and sediment controls, :inlet protecti6h/control at storm drains, diversion structures): Lyndon Steel Company LLC has sheds in place to eliminate rain water nflicing-with 55 gallon drums of paint. Part.2 - Miscellaneous I - Any evidence of discharge to receiving waters/MS4? (e-g.: stormwaterrunoff, dry weather:discharge, co- .mingling:o-fprocess wasiewaier): NYes ❑No - The Storm atef, Discliarge-0utfalls`foir LLyadairtSteO Corn"ny'LLC discharges to:Swa m Creekhickjs in'the Yadkin river watershed. 2) Do:the stormwater outfalls on-sitecorrespond'with those'listed.on:the site map -and iia'SPPP? ®Yes ONo Yes, the.-starmwater_-outfalls on -site correspond with those listed on the:site'map and in SPPP, but=the'site:.map�is°missing the potential'.pollutants that could be. discharged and the Ohysicaflocaiion for both.outfalis. Also, the latitude.and.longitude are missing from.the site maP- -3) Summary of.Siorniwater-,Discharge�0utfalls SDOIdentification PotentWTO'llutants°that -Physical Location Latitude -and Longitude could be -discharged 9 ? OutfallI _ Outfall 2 Part 3 — SPPP Review can be:campleted in office' Site Overview Yes No. Notes ,Is.there a SPPP? Daes'SPPP iriclude.a=certificatioii`stateuient`by the responsible ✓' Please li'rovide.and update. corporate officer?, the signed certification statement byTtbe=responsible co orate officer. Does the:general rriap°depiit the:facility's location on.a USES ✓ Please add the:receiving .quad map.(or equivalent imp) with. receiving waters.,(or MS4) waters on ge&ral niap listed? and include that! Swaim. creek is not a TMDL stream. Ide_ntification.of impaired waters or watershed (if applicable)? _ ✓ Please.include in SPPP that Swaim creek is nofan ini 'eised.streani: Narraiive.Description pf these- Indusiiial Activitim, . :.Storage,Praictices •Unloading/Loading Activities Outdoor Processes Particulate,Generating/Control Processes ✓ Waste.Disposal Does site' map denote drainage,rtezi s: f1d direction; ✓ boundaries, %'impervious,,and structures? Also includes SDOs, industrial activi 'afeas; arid site to • o ra _h ? A -list of ii�ajprspill: that -Have occurred`within the past three ✓ Noue in the past three,years. ye (with.corrective; actions to revent futures ills)j sectiiin 2.2.. ,A sig�ied apnual''certificatiori that tliefacility hi4ieeii':tested 'for ion=. ✓ `Please prfiduce a`signedl •stormwaier discharges6i & site?` annual'cerEification that the facility -has : been:testedfor non=stormwat_er discharges from�the site Comments; NOTE: PleasevNitte,the.City`of Winstori'Salem,.Stormwater Division's contact infornfdtioitto Lyndon Steel Company LLC:Spill -Notification List. The contact -for spill notitiotion W Mr Keith Huff; Stor wvater Directo-t.`(336)'747:-6962 = landline;.,(336) 406- 3332 =,cell phohe,niinnber. Mr_. Huffs etnail.address. is keithhl(,4cityofvvs:or for providing written_no* tif cation'.; Stormwater Management Strategy Yes No Notes Does SPPP incorporate the Thine ' baseline controls: Fe sibilit c revieW,to as y Study- (technical &.econorni min im ivd, pollutant expowre) Sed(5ndary'C,bi1taii.u.'n.ent,(Iabic summary oftank . s,.stur,e,d:rnaten`aJs. re . lease records) . I I BN4P Summary (listing of site structuraunonstructuirid practices) SPRP.& Proc.edures (identified;-rcsponsibie' personnel w/.signatures 8: dated) PM & GH , (insp-Wioh of ma.tefial handling areas & regular cleaning schedules) Facility- Inspections (biannual inspections of ficility and all stormWater systeryis) Employee Training!(ann.ual basis f6r si.aff who perform.SPLP and PM.fimctions) Responsible Party idon(s)=develop.ing,.im0lementing.,& revising SPPP,) Aniendinent- & Ahnual Update (of rajii.q)ius. n6ftswhows. Bmqsftiirig data V ✓ If a . pojicable please provide V ✓ No'signature and no.date& V Employee training was last -held on 6/27/2013. No-,sigpature,or'no'datm V, Dbes.SPP.P:6ontai'n-_comt)ieted routine inspection reports/records regarding reportAle, i mplementation. ofthe nine baseline: controls (i.e. SPPNmoleradhiation)? TI Analytical Monitoring Yes No Notes Are samples Cibill6add within '30:minutes of'm'-dasui-able;radh events ✓ and at'least U hours since -the, last storm_gved? Are sampling &;vefits, 60,days apart? (F-kCi.P.,OON: -Tier 2 . A.3yesponses) ✓ Lyndon Steel ColOpal.11 Y LLC. is currently, operating on a Tier I samplihg.cycle. Is'ahbtlytical ffi6riitijrihg compl6ie (irf6lading schedule) for each ✓ In the past Yyeirs,,theie :SDO?-(EXCEMON:-ROS) has b-een-no,anidytical monitoring discharge characteristics, for Copper and Zinc V, Any -exc6edehci-,sVf Pollutantpararnet&is`when compared against.the permit, benchmark values? NIA Ha'Fkilitv iffivlehhehted'aopropfiate, -§Oe6ted actions to f&.ducie pollutant concentrations, in response to. benchmark- exceedehces (if applicable)? Qualitative Monitoring Yes No , Notes Is -qualitative m6nit-drin'g" beilirlg,verf6im4d during'. events? Is quiliiaiivemoniio' ring- complete "(including schedulq)'fbr each SDO7 Are mohit6fing events 60 days apart? (EXCEPTION: Tier 2& 3 responses) ✓ Any,qbservable. &xcessive.amoufits 6f'p.611iftarit indicato-rs-' in stormwater disbhdrge'At SDOs? Part 4 —Required Actions to be completed by Facility: 1. Immediately clean upsoii at leak.the receiving bay and increase cleaning frequency to weekly, as' per your Good Housekeeping Program- requirements. In order to -prevent stormwater pollution, please,produce anew BMP`concerning oil spots at receiving hay. 2. 'Replace old dumpster with new dump'ster,.and ensure thaVa drain plug is inserted in the new. dumpster. 3i Please provide andupdate the signed; rtification state"m_ent by the responsible corporate,officer_in the-SPPP. A. 'Please add the receiving-waters.otr genera l:na.ap',and include that Sr�vaiiiu creek is'bot`a TMDL-stream. Also, please include in the'SPPP that -Swaim creek,is not:an impaired :stream. S: Piease provide.a signed, annual certification that Lyndon=Steel,Company LLC has been tested for non-stormwater dischaiges €romAhe_site.and•'inch2ded it in the SPPP. 6. Please dpdste-tlie` W. of Winston Salem, Stormwater Division's contact information to:Lyndon SteelCow papy's-LLCSpili Notification-;i.ist 7. Please update;and resign the Management Approval Statenbient and Cei'tifying engineers' stateme.nt.in SPPP. 8. Update and sign theSpill Prevention: and, Response Procedures in-SPPP. '9. Provide -employee training for staff who will perform spill response procedures and' .preventive;maintenanceifunctions byihe due'date of this=inspection package. 10: Update and, sigh .the Responsible Pa iffy section of, the SPPP. 11. starin9 next'sampling event, please test foe'a11 analyticalMonitonng discharge characieristi&r_ei quired, including CoppWand'Zinc. Once this -item has been established, please.email documentation'.showing all analytical monitoring discharge characteristics -required were. 12.;Determine=if Lyndon Steel Company-LLC requires a-Solveni Management Plan1rom NCDNER.=tf.so, please update -the SPPP and. test for Total_Toxic Organics: starting next sanipltng`event ;If not,.please'tpciuSde the TTO,sanipiing-waiver on each -discharge monitoring report. -This iriformiatiorijs located in -part iI'page74 of 10 in the NCG030000.permit: 13. Denote the pby_skaTlocation,potential;poqutants-that.could; be -discharged; and the' ,latitude:and`longitude:of the Stormwater.'Discharge Outfalls,1-and 2i in SPPP;and,on site.map. 14. Concerning secoindary containments,. please,provide:an.annual table summary.of tanks,•stored:materials, and•rehikse•records. Pictur,,e,-#1 Oil.swat,fe receiving bay Immediately clean up,oil,at leak4he.receivingbay and -increase cleaning frequency to weekly,, as.per your Good Housiekee'lihij,Pr6gram r'eq'iiiitihit."iii'b'idir'to p�evelit,sto*r'ln'�vat�'r,00llq#on, - fii . .1 1 . 'f .. .11I . . please produce -a he,W-BW concerning oil,spots-at receivin''g'bay.. Rephiti-6ld-duthpter-.With niew, dunipster. -abd ens u re. that wdrain'Olug'is inserted inIthe,hew'dump9ter. 'C,o'mpj*iy Reprie!§enfati.ve(s) thgroajjiqipaW inlnspe6ion; Mrs-XbdifiAte Macbren Stait,of Inspection: -9:668M Completion. of• Inspectiom-, 11: 00 gate: 7130/2014 Sighaftird of, Stortnwateilnspect6r: Title: S.tormwat.er Inspect6r' /4.. lSIJ Winston-Salem Public Works Department StormwaterlErosion and Sedimentation Control Program City of WiUmon-salcm P.O. Sox 2511 wi=on-salcm. NC 27102 Ciryunk 311 (336.727.BDDD) Fu 336.799.3173 August 13, 2014 Mrs. Christine Maclaren Human Recourses Lyndon Steel Company LLC 1947 Union Cross Rd Winston-Salem, N.C. 27107 Dear Mrs. Maclaren: The Stormwater Division of the City of Winston-Salem would like to thank you for your time and professional courtesy regarding the July 30, 2014 inspection of Lyndon Steel Company LLC... As per your request, a copy of the completed surface water inspection form has been enclosed to you. Part 4 of this report (Required Actions to be completed by Facility) contains Annotations 41-#14 that Lyndon Steel Company's LLC must complete. Please provide documentation that verifies Lyndon Steel Company's LLC successful completion of the corrective measures to me by .No vc>»rber 13. 2014. The Stormwater Division reserves the right to enter and inspect Lyndon Steel Company's LLC as often as necessary to determine compliance with permit requirements of NCG030474. Thank you for your continued support and implementation of the City of Winston- Salem's Stormwater Program. If you have any questions, please feel free to contact me at (336) 747-6964. Sincerely, Ladonta Clark Stormwater Inspector Phone: 336.747.6964 Cell: 336.416.2403 Fax: 336.748.3173 C.c-ol- .M yor Allen Joins; %lvian H. Bwkc. Mayer Pm Tempom. No.d t Ward: Denise D. Adam> Horih Ward; Dan Ewe. Swth�Ward Raberr C M& Wm Ward: W4 i.e &. Sourb Wird; Wanda McrvJ4 Northwast Ward: Derwin L Wncp=m Eau Ward; jams Taylor. Jr.. Soudan Wan'; City Maaagr.1 a D. Qrriry Call 311 or 336-727-8000 citylink@cityofws.org (W %t Stormwater/Erosion Control Division Surface Water Inspection for Industrial Sites General I_nfor_matioo A) Official Company Name: Lyndon Steel —Company LLC B) Physical Address: 1947 Union Cross Rd, Winston-Salem, N.C. 27107 C) Telephone Number: Office 336-785-0848 ext. 218 D) Mailing Address, if different from above address: E) Authorized contacts to represent company in environmental regulatory issues: Primary contact: Mrs. Christine Maclaren Title: Human Recourses Manager Contact number(s): Office (336)-785-0848 ext. 218 Cell (336)-972-0436 Email address: cmaclaren@lyndonsteel.com Secondary contact: David Reid Title: Plant Manager Contact number(s): Office: 336-785-0848 ext. 228 Ceilphone: 336-399-2103 Email address: Dreid@lyndonsteel.com F) SIC Code Number of business: Fabricating of Metal Products (SIC 34) G) NC Stormwater NPDES Permit Number: NCG030474 Permit Category: (General) Fabricating of Metal Products H) Any other control authority permit(s) (air quality control, wastewater, hazardous waste) & number(s): 1) Air quality Permit: 00894 2) Hazardous waste permit NCR 000011072 I) Brief description of industrial activities that occur on -site: The fabrication of steel products that are sold for commercial purposes. I) Ultimate Receiving Waters: Swaim Creek TMDL stream ❑Yes ©No Part 1 - Stormwater Controls- 1. Best Management Practices a. List the nonstructural controls employed by the facility: 1. The paint storage area has a shed over the products to prevent stormwater pollution. 2. The maintenance shed is covered to protect items such as gas cans, weed eaters, lawnmowers, and other machines. b. Are the BMPs reasonable & appropriate for the facility? ZYes ❑No Comments Immediately clean up oil at leak the receiving bay and increase cleaning frequency to weekly, as per your Good Housekeeping Program requirements. c. Are BMPs installed correctly, maintained, and effective operating condition? ®Yes ❑No Comments The Secondary tanks used for gasoline/kerosene are properly maintained. 2. Provide a brief description of other controls that manage/prevent/minimize storrnwater runoff (e.g., erosion and sediment controls, inlet protection/control at storm drains, diversion structures): Lyndon Steel Company LLC has sheds in place to eliminate rain water mixing with 55 gallon drums of paint. Part 2 — Miscellaneous 1. Any evidence of discharge to receiving wateWMS4? (e.g.: stormwater runoff: dry weather discharge, co - mingling of process wastewater): ®Yes ❑No The Stormwater Discharge Outfalls for Lyndon Steel Company LLC discharges to Swaim Creek, which is in the Yadkin river watershed. 2) Do the stormwater outfalls on -site correspond with those listed on the site neap and in SPPP? ©Yes ❑No Comments Yes, the stormwater outfalls on -site correspond with those listed on the site map and in SPPP, but the site map is missing the potential pollutants that could be discharged and the physical location for both outfalls. Also, the latitude and longitude are missing from the site map. 3) Summary of Stormwater Discharge Outfalls SDO Identification Potential Pollutants that Physical Location Latitude and Longitude could be discharged 9 ? . 7 Outfall 1 . Outfall 2 .Part 3 — SPPP Review (can be completed in office) Site Overview Yes No Notes Is there a SPPP? ✓ Does SPPP include a certification statement by the responsible ✓ Please provide and update corporate officer? the signed certification statement by the responsible corporate officer. Does the general map depict the facility's location on a USGS ✓ Please add the receiving quad map (or equivalent map) with receiving waters (or MS4) waters on general map listed? and include that Swaim creek is not a TMDL stream. Identification of impaired waters or watershed (if applicable)? ✓ Please include in SPPP that Swaim creek is not an impaired stream. Narrative Description of these Industrial Activities: Storage Practices f Unloading/Loading Activities '/ Outdoor Processes Particulate Generating/Control Processes ✓ Waste Disposal ✓ Does site map denote drainage items: flow direction, ✓ boundaries, % impervious, and structures? Also includes SDOs, industrial activity areas, and site to o ra hy? A list of major spills that have occurred within the past three ✓ None in the past three years years (with corrective actions to prevert futures ills)? section 2.2. A signed, annual certification that the facility has been tested for non- ✓ Please produce a signed, stormwater discharges from the site? annual certification that the facility has been tested for non-stormwater discharges from the site NOTE: Please update the City of Winston Salem, ,Stormwater Division's contact information to Lyndon Steel Company LLC Spill Notification List. The contact for spill notification is: Mr. Keith Huff, Stormwater Director (336) 747-6462 = landline (336) 406- 3332 = cell phone number. Mr. Huff's email address is kcithhl(2,citVofws.o!:g for providing written notification. Stormwater Management Strategy Yes No Notes Does SPPP incorporate the nine baseline controls: Feasibility Study (technical & economic review to minimize pollutant exposure) Secondary Containment (table summary of tanks, stored materials, release records) BMP Summary (listing of site structural/nonstructural practices) SPRP & Procedures (identified, responsible personnel wl signatures & dated) PM & GH (inspection of material handling areas & regular cleaning schedules) Facility Inspections (biannual inspections of facility and all Stormwater systems) Employee Training (annual basis for staff who perform SRP and PM functions) Responsible Party (specific position(s)-developing, implementing, & revising SPPP) Amendment & Annual Update (of major spills, nonsw flows, 13MPs, sampling data ✓ If applicable please provide ✓ No signature and no dates. Employee training was last held on 6/27/2013. ✓ No signature or no dates. Does SPPP contain completed routine inspection reports/records regarding reportable implementation of the nine baseline controls (i.e. SPPP 4n lementation)? Analytical Monitoring Yes No Notes Are samples collected within 30 minutes of measurable rain events ✓ and at least 72 hours since the last storm event? Are sampling events 60 days apart? (ERUPTION: 'tier 2 & 3 responses) ✓ Lyndon Steel Company LLC is currently operating on a Tier 1 sampling cycle. Is analytical monitoring complete (including schedule) for each ✓ In the past 3 years, there SDO? (EXCEPTION: ROS) has been no analytical monitoring discharge characteristics for Copper and Zinc Any exceedences of pollutant parameters when compared against the permit benchmark values? N/A Has Facility implemented appropriate, selected actions to reduce pollutant concentrations, in response to benchmark exceedences (if applicable)? Qualitative Monitoring Yes No Notes Is qualitative monitoring being performed during measurable storm ✓ events? Is qualitative monitoring complete (including schedule) for each ✓ SDO? Axe monitoring events 60 days apart? (F.XCET nON: Tier 2 & 3 responses) ✓ Any observable, excessive amounts of pollutant indicators in stormwater discharge at SDOs? Part 4 -- Required Actions to be completed by Facility: 1. Immediately clean up oil at leak the receiving bay and increase cleaning frequency to weekly, as per your Good Housekeeping Program requirements. In order to prevent stormwater pollution, please produce a new BMP concerning oil spots at receiving bay. 2. Replace old dumpster with new dumpster, and ensure that a drain plug is inserted in the new dumpster. 3. Please provide and update the signed certification statement by the responsible corporate officer in the SPPP. 4. Please add the receiving waters on general map and include that Swaim creek is not a TMDL stream. Also, please include in the SPPP that Swaim creek is not an impaired stream. 5. Please provide a signed, annual certification that Lyndon Steel Company LLC has been tested for non-stormwater discharges from the site and included it in the SPPP. 6. Please update the City of Winston Salem, Stormwater Division's contact information to Lyndon Steel Company's LLC Spill Notification List. 7. Please update and resign the Management Approval Statement and Certifying engineers' statement in SPPP. 8. Update and sign the Spill Prevention and Response Procedures in SPPP. 9. Provide employee training for staff who will perform spill response procedures and preventive maintenance functions by the due date of this inspection package. 10. Update and sign the Responsible Party section of the SPPP. 11. Staring next sampling event, please test for all analytical monitoring discharge characteristics required, including Copper and Zinc. Once this item has been established, please email documentation showing all analytical monitoring discharge characteristics required were. 12. Determine if Lyndon Steel Company LLC requires a Solvent Management Plan from NCDNER. If so, please update the SPPP and test for Total Toxic Organics starting next sampling event. If not, please include the TTO sampling waiver on each discharge monitoring report. This information is located in part II page 4 of 10 in the NCG030000 permit 13. Denote the physical location, potential pollutants that could be discharged, and the latitude and longitude of the Stormwater Discharge Outfalls 1 and 2, in SPPP and on site map. 14. Concerning secondary containments, please provide an annual table summary of tanks, stored materials, and release records. Picture #I OH spot at receiving bay Immediately clean up oil at leak the receiving bay and increase cleaning frequency to weekly, as per your Good Housekeeping Program requirements. In order to prevent stormwater pollution, please produce a new RMP concerning oil spots at receiving bay. Picture# 2 Faulty trash dumpster near office Replace old dumpster with new dumpster, and ensure that a drain ping is inserted in the new dumpster. Company Representative(s) that participated in inspection: Mrs. Christine Maclaren Title(s): Human Resources Manger Start of Inspection: 9:00am Completion of Inspection: 11:00 Date: 7/30/2014 Signature of Stormwater Inspector: Title: Stor_mwater Inspector Compliance Inspection Repo Permit: NCGO30474 Effective: 11/01/12 Expiration: 10/31111 Owner: Lyndon Steel Company SOC: Effective: Expiration: Facility: Lyndon Steel Company County: Forsyth 1947 Union Cross Rd Region: Winston-Salem Winston Salem NC 27107 Contact Person: Michael A Carded Title: Phone: 336-785-0848 Directions to Facility_ System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection [Date: 0713012014 Entry Time: 09:OOAM Primary Inspector: Aana Taylor -Smith Secondary Inspector)s): Certification: Phone: Exit Time: 11:00AM Phone: 33$.771.5000 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 k� permlL NCGO30474 Owner • Facility: Lyndon Steel Company inspection Date: Q713Q1 014 Inspection Type : Compliance Evaluation Reason for Visit_ Routine Inspection Summary: Refer to local program inspection package. Page: 2 Permit: NCG030474 owner - Facility: Lyndon Steel Company Inspection Date: 0713OM14 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? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? M ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # 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? ❑ M ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ M ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? M ❑ ❑ ❑ Comment: Refer to local program inspection package. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: Analvtical monitorina does not include parameters from most recent permit (copper and zinc Facility will conduct analytical monitoring with new parameters at next sampling event. 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? ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ # Has the facility evaluated all illicit (non Stormwater) discharges? ❑ 0 ❑ ❑ Comment: Refer to local program inspection package. Page: 3 LYNDON STEEL COMPANY qF iffff 1947 Union Crass Road Winston-Salem, NC 27107 g " ���s�r. ne�onsteel.com PHONE: (336) 785-0848 FAX- (336) 788-8835 fWnosP �`' www.lyndonsteel.com June 4, 2013 Mr. Ron Boone Winston-Salem Regional Office NC Department of Environment and Natural Resources Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Dear Mr. Boone: On behalf of Lyndon Steel Company, I hereby submit this response to NCDENWs Notice of Deficiency (NOD-2013-PC- 0153). 1. General Location Map and Site Map - our safety consultant, Operations Excellence, is in the process of making the necessary corrections to the maps. This item will be corrected by June 30, 2013 and I will send of a copy to you for approval. 2. Spills List - as part of our annual review process, we will consolidate the individual spill records into one statement. This item will be completed 3. Inspections - semi-annual inspections were conducted in 2010, 2011 and 2012; see attached records. I will take immediate responsibility for ensuring these records are properly maintained. 4. Employee Training - in conjunction with Operations Excellence, employee training will be completed annually. Training for 2013 is already scheduled for June 13, 2013. I will take responsibility for ensuring records are properly maintained as part of our program. 5. Monitoring - see attached records. I will take immediate responsibility for ensuring these records are properly maintained. If you have any questions, please contact me at 336.785.0848 ext. 218. Sincerely, Christine MacLaren Human Resources Manager Lyndon Steel Company I N�rrbO�41 rE�a NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P. E. John E. Skvarla, III Governor Director Secretary April 22, 2013 Lyndon Steel Company Attn: Christine McLaren 1947 Union Cross Road Winston-Salem, NC 27107 SUBJECT COMPLIANCE EVALUATION INSPECTION & NOTICE OF DEFICIENCY NOD #: NOD-2013-PC-0153 NPOES General Stormwater Permit NCG030000 Certificate of Coverage: NCGO30474 Facility: Lyndon Steel Co., 1947 Union Cross Road, Winston-Salem, NC 27107 Forsyth County Dear Ms. McLaren: Ron Boone, of the NC Division of Water Quality'(DWQ or the Division), Winston-Salem, Regional Office (WSRO), conducted a compliance evaluation inspection (CEI) at the subject facility for the subject permit/Certificate of Coverage (COC) on April 11, 201.3. The assistance and cooperation of Mr. Michael O'leary was greatly appreciated. The inspection findings are summarized below and on the attached inspection report. The facility is located at 1947 Union Cross Road, in Winston-Salem, Forsyth County, NC, at approximately coordinates 36.0444580N,-80.1385690W. Stormwater related to industrial activity is discharged from stormwater discharge outfalis (SDO) 001 and 002 to an unnamed tributary (UT) to Swaim Creek, which is currently classified as a Class C water located in the Yadkin Pee -Dee River Basin. Documentation and Monitoring Review Lyndon Steel Company (Lyndon) has a good stormwater pollution prevention plan (SP3), however, Mr. Boone noted the following deficiencies: • The General Location Map (GLM) does not meet all requirements specified in Part II, Section A, Paragraph 1(a) of the NCG030000 general permit. Specifically, the GLM does not specify whether. the receiving stream, Swaim Creek, is impaired, or whether a Total Maximum Daily Load (TMDL) has been established. + The Site Map (SM) does not meet all requirements specified in Part il, Section A, Paragraph 1(c) of the NCG030000 general permit. Please note that this is a repeat finding from the previous inspection in January, 2010. Specifically, the SM does not show the correct location of the two aboveground storage tanks (AST), the outside painting area, the waste material storage area, or the percent of impervious surface for each drainage area. North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown at. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771-46301 Customer Service;1-877.623.6748 Internet; www.ncwaterquality.org Nne orthiCarolina Natma!!y An Equal opportunity 1 Affirmative Action Employer Lyndon Steel Company Attn: Christine McLaren Compliance Evaluation Inspection, NCGO30474 NOD-2013-PC-0153 April 22, 2013, Page 2 of 2 • The spills list, as required by Part II, Section A, Paragraph 1(d), does not appear to have been updated annually, as required by Part II, Section A, Paragraph 8 of the NCG030000 general permit. However, the site does use individual spill records, which shows that spills are being recorded as'required. We suggest that you simply provide an updated spills statement as part of your annual SP3 review. • The only records found of the seirti-annual facility inspections required by Part 11, Section A, Paragraphs 4 and 5 of the NCGO30000 general permit, were from 04/2007, 10/2007, one from 2008, 04/2009, and 09/2009, These inspections should be conducted twice per year, once in January — June and once in July —December. • The only records found of the annual employee training required by Part 11, Section A, Paragraph 6 of the NGG030000 general permit, were from 2012. Stormwater pollution prevention training should be conducted once per year. • Records of the qualitative and analytical monitoring (QM and AM, respectively) required by Part II, Sections B and D of the NCG030000 general permit, were available'for 2010, 2011, and 2012. However, these records must be kept of file for five years. There were additional records for 2004 — 2006, but records for 2007 — 2009, were missing. Site Review The entire site and SDOs were clean and well maintained. Mr. Boone noted no concerns. The Division requires the Lyndon corrects the deficiencies outlined above as soon as practical. Please reply in writing to this letter within 30 business days of receiving it. Your written reply should address each of the deficiencies noted above and provide detailed corrective actions plans with implementation schedules for each deficiency. Lyndon is reminded that violations of the NCG03.0000 permit are subject to civil penalty assessments not to exceed $25,000 per day/per violation.'. If you have any questions regarding the inspection or this letter, please feel free to call Mr. Boone at 336- 771-5000. Sincerely, J W. Corey Basinger Water Quality Regional Supervisor Winston-Salem Region Division of Water Quality Attachments: .1. BIMS Inspection Checklist Cc: (1, SWP-WSRO1 2. Central Files 3. Stormwater Permitting Unit i Compliance Inspection Report Permit: NCG030474 Effective: 11/01/12 Expiration: 10131117. Owner: Lyndon Steel Company SOC: Effective: Expiration: Facility: Lyndon Steel Company County: Forsyth 1947 Union Cross Rd Region: Winston-Salem Winston Salem NC 27107 Contact Person: Michael A Carcieri Title: Phone: 336-785-0848 Directions to Facility: System Classifications: Primary ORC: - Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/11/2013 Entry Time: 09:00 AM Exit Time: 11:00 AM Primary Inspector: Ron Boone Y,1�3Phone: 336•-771-4967 �ZSecondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge CQC Facility Status: ❑ Compliant ■ Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCGO30474 Owner - Facility: Lyndon Steel Company Inspection Date: 04111/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Please refer to the attached inspection summary letter. Page: 2 1 Permit: NCG030474 owner - Facility: Lyndon Steel Company Inspection Date: 04/11/2013 Inspection Type: Compliance Evaluation Stormwater Pollution Prevention Plan 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? # 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: Please refer to the attached inspection summary letter. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Please refer to the attached inspection summary letter. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Please refer to the attached inspection summary letter. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Reason for Visit: Routine Yes No NA NE Yes No NA NE ■nnn Yes No NA NE ®nnn nn■n Yes No NA NE nnnn Ell nnn nnnn nn❑n Page: 3 NCG030000 Inspection Checklist AREA YES NO N/A N/E REMARKS I. STORMWATER POLLUTION PREVENTION PLAN (SP3) [Part II, Section A] A. GENERAL LOCATION MAP (GLM) [Part II, Section A, Para 1(a)] 1. Facility's location; transportation routes; surface waters? 2. Name of MS4 and/or receiving stream? I/ 3. Accurate lats/longs for each SDO? ]/ 4. Receiving stream impaired/TMDL? B. NARRATIVE DESCRIPTIONS [Part II, Section A, Para 1(b)] 1. Storage practices? 2. Loading/unloading activities? v 3. Outdoor process areas? 41 4. Dust/particulate generating/control processes? 77 S. Waste disposal practices? 6. Potential pollutants for each SDO? r/ C. 51TE MAP (SM) [Part II, Section A, Para 1(c)] e;7r ` w ra n ,p /GCe cc-,'! 51'" 1. Site Boundary? 2. 5DOs? Z �'<� �iH s►/I ►2svf Pt ,S� 3. On site/adjacent surfar_e waters/wetlands? 7- 1, It's oDJ rm L,, 4. Industrial activity areas: 71).q a. Material storage areas? Sy;4 b. Disposal areas? r/ / C. Process areas? d. Loading/unloading areas? e. Haul roads? S. Site topography/finished grade? 6. Drainage features/structures? 7. Drainage area boundaries for each SDO? 8. Buildings? 9. Stormwater Best Management Practices? 1./ 10. Percent of each drainage area that is impervious? 11. Graphic scale indicator/drawn to scale? / 12. North arrow? D. SPILLS LIST [Part II, section A, Para 1(d)] 1. List of significant spills/leaks over previous three years? j S .af�n,Gh� - b K i f"oe nrfl/an 2. Corrective actions for each spill? A e Q LA r 6, 4-1- ' 3. Updated annually? [Part !I, Section A, Para 8(a)] ,�%vt "Aoil 1p� %sc / 4 , i% r e an- e®r E. SDO CERTIFICATION [Part II, Section A, Para 1(e)] S A br y CA -cj' ct i n U 3 6 7, j Co ve, rJ e, / / , -S 1. jAnnual SDO certification? 011j s"h a JV - h A 2. ISigned in accordance with Part III, Section B, Paragraph 5? ✓ i-�G!ica 7�d arc �.. D!1 / F. FEASIBILITY STUDY [Part II, Section A, Para 2(a)] 1. Annual review of feasibility of eliminating/reducing exposure? / V [GT.SECONDARY CONTAINMENT (SC) [Part Il, Section A, Para 2(b)] 1. All SC provided as required? 2. Table listing all SCs and materials stored? ✓ 3. Locked drain valves provided as required? ✓ 4. Proper SC drainage records kept for 5 years? //i%i7G A14 y�1)-3_ PC -blS3 Y" Page 1 of 4 Bookl.xlsx 4/18/2013, 1:51 PM AREA I YES/ NO IN N/E REMARKS H. BMP SUMMARY [Part II, Section A, Para 2(c)] V 1. jAnnually updated list of structural/non-structural BMPs? 2. lRationale for use of each BMP? I. SPILL PREVENTION/RESPONSE PROCEDURES (SPRP) [Part II, Section A, P t.� 1. Assess potential pollutant sources? 2. Responsible personnel listed? I/ 3. Signature/date of each responsible person (RP)? 4. At least one RP on site at all times? J. PREVENTATIVE MAINTENANCE/GOOD HOUSEKEEPING PROGRAM (PMGH) [Part II, Section A, Para 41 & FACILITY INSPECTIONS [Part 11, Section A, Para 5] 1. Address all areas? 2. Provide schedule(s) for PMGH activities? I/ 3. Inspections conducted semi-annually (Jan -Jun & Jul -Dec)? ✓ a7 4. At least 60 days between inspections? t/ K. EMPLOYEE TRAINING [Part 11, Section A, Para 6] 1. All appropriate personnel trained annually? 1/ 2. Training RPs indentified? 3' Training documented with signature/date of each trainee? V Qh fit 5/il 11 k r G fA owc �� l?� s�' � L. RESPONSIBLE PARTY [Part 11, Section A, Para 71 r / 1. 1 RP(s) identified for overall SP3? 2. RP(s) identified for different components of SP3? M. SP3 AMENDMENT/ANNUAL UPDATE [Part 11, Section A, Para 8] 5� 3 1. SP3 amended as required? 2. SP3 reviewed/updated annually? 3. Include updated spill list? 4. Include SDO recertifications? ✓ ✓ 5. BMP review? 6. Required annual training conducted? 7. Review year's analytical data/tiered actions? 10/ N. SP3/BMP IMPLEMENTATION [Part II, Section A, Para 9] I. JSP3 implemented? 2. 1 BMPs implemented? +/ O. SOLVENT MANAGEMENT PLAN (SMP) [Part II, Section A, Para 10) 1. Annual inventory of toxic organic compounds on site over previous three years? A�/b /i•U� %a S�G�P T� U , 2. Narrative description of locations/uses/disposal methods? 3. Quantified inventory of compounds disposed on & off site? 4. List of BMPs employed to prevent spills/leaks? 'r Page 2 of 4 Bookl.xlsx 4/18/2013, 1:51 PM R:ANALYTICAL • • QUALITATIVE MONITORING• ' • ' M. • . 1 1 . _ mmmmmmm�m Enter �------------------- Year 11 Below 07 Enter Year 1 , ��--�_----------�--- BelowI �------------------- 1 , -- •' 1 mmmm mmmmm i Enter Year 1 ©------------------- Below /01 I1 ©------------------- Page 3 of 4 Bookl.xlsx 4/19/2013, 1:51 Pull m� mmmmmmmmm Enter Year , �� ' • mmmmmmm�m Enter Year Below ion ®--®I�% Enter Year i Below "&CI WO cv?, �p use sd /v&I k-3. 3( '29S O� Page 4 of 4 Rookl.xisx 4/18/2013, 1:51 PM x-;` " A w� NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Division of Water Quality Coleen H. Sullins Director January 12, 2010 Lyndon Steel Company Michael Carcieri, Senior VP, Production/Quality Control 1947.Union Cross Road Winston-Salem, North Carolina 27107 Subject: NOTICE OF VIOLATION Stormwater Inspection Lyndon Steel Company Permit No. NCG030474 Forsyth County Dear Mr. Carcieri: Dee Freeman Secretary Enclosed please find a copy of the Inspection Report from the inspection conducted January 7, 20,0!f. The Stormwater Inspection was conducted by Steve Mauney of the Division of Water Quality (DW% Winston-Salem Regional Office. Christine Maclaren and Mike O'Leary, Lyndon Steel assisted with the site inspection. The inspection consisted of two parts: an on -site inspection of the facility and a limited file review. The following are the findings from the subject inspection. The facility vvas found to be in violation of permit NCGO30474 for the following: Inspection Area Compliance Issues Storm Water Plan Failure to include an annual update to the SWPPP with a Recertification that outfalls do not contain non-stormwater discharges StormWater Plan The map was not current. Stormwater Data Data was not previously submitted to DWQ for this facility. I. Permit The Certificate of Coverage NCG030474 for the Lyndon Steel Company -Winston Salem facility became effective 'November 1, 2007 and expires on October 31, 2012. The permitted facility is authorized to discharge stormwater from a facility located at 1947 Union Cross Road, Winston Salem, North Carolina to receiving waters designated as a Tributary to Sawmill Branch, a class C stream in the Yadkin -Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in General Permit No. NCG030000. Any other point source discharge to surface waters of the state from this facility is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization or approval. North Carolina Division of Water Qual'ry, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 OnePhone, 336-771-50001 FAX: 336.771-48301 Customer Service: 1-877-623-6748 NorthCarolina Internet: wvM�,r�mvaterquaTity.arg �f�tirrr�ll� An Equal opForlonily t Aflrmake Action Employer Lyndon Steel Co. The permit identifies two monitoring requirements that apple to this facility: ➢ Qualitative Monitoring for Stormwater Discharge Outfalls per Part II, Section C. 9 Analytical Monitoring for Stormwater Discharge Outfall per Part II, Section B. Copies of the NCG030000 general permit documents can be accessed from the following web page: htto:Ifh2o.enr.state. ne.uslsu/Forms Documents.htm#StormwaterGP II. Records/Reports General Permit NCG030000 requires certain monitoring to be documented and the records maintained at the facility. The following records are required at this site per the NPDES permit: Stormwater Pollution Prevention Plan as specified per Part 11, Section A. 2, Stormwater Discharge Outfalls (SDO) shall have Qualitative monitoring performed as described in Part II. Section C and Table 4. 3_ Stormwater Discharge Outfalls (SDO) shall have Analytical monitoring performed as described in Part 11, Section B and Tables 1 & 2. A review was made of the supplied records and reports for the Lyndon Steel Company facility for the period November 2007 through the present. This review indicated deficiencies in the following records: The Stormwater pollution prevention plan was incomplete. o The plan was updated in 2007, but there was no documentation that the plan had been reviewed or updated since that point. "The annual update shall include re -certification that the stormwater outfalls have been evaluated for the presence of non-stormwater discharges." o The site map should be updated to show the correct location of the 2 AST's and the diked paint and waste material storage area. The map should also be updated to include the location of Outfall 92. o The percentage of impervious area draining to each outfall and the total drainage area for each outfall must be listed on the map. o If the outside painting is resumed in the future, the location of that activity must be specified on the map. The plan should list the specific measures that will be implemented to prevent contamination of stormwater from an outside painting process. o Correct the plan in section 8.2 to indicate that stormwater monitoring will be conducted according to the permit. The current plan indicates that sampling is not required. o Appendix D of the plan refers to reporting discharges to the County Health Dept. and an), spills of 1000 gallons. The North Carolina reporting requirements include any spills that reach surface waters, any spills that exceed 25 gallons, any spills that are closer than 100 feet from surface waters and any spills that are not cleaned up within 24 hours of the discharge. Attached is GS 143-215.85 (b). The Quantitative data has not previously been submitted to this Division. Lyndon Steel Co. The semi-annual data was in the plan and indicated compliance with benchmark values. However, this data ,vas not being submitted to the Division as of this inspection. 111. Facilih, Site Review Mr. Mike O'Leary, Lyndon Steel Company was present during the records review and for the tour of the facility. At the time of the inspection two waste bins for scrap metal were covered with tarps and were currently empty. At the time of the inspection the outfalls were observed to be free of industrial litter or debris - Please refer to the enclosed Inspection Report for any additional observations and comments. Carefully review these violations and deficiencies and respond in writin4 to this office within thirty (30) _work-in; day of _receipt of this letter. You should address the causes of noncompliance and all actions taken to prevent the recurrence of similar situations. Your response should include the following: Describe steps taken to satisfy the requirements of the NPDES General Permit, as listed above, immediately. Please explain your failure to implement these requirements and discuss how these requirements -,Fill be met in the future. > Provide this office with the updates to your completed Storm -water Pollution Prevention Plan within the required response time noted above. A guidance document to assist you in developing the updates to your Stormwater Pollution Prevention Plans for Stormwater Runoff at Industrial Activities is available at the Division v,,ebsite. http;//h2'o.enr.state.nc.us/su/Manuals_Factsheets.htm Provide anv other relevant factors_ ti-..hich you believe, should be considered. Thank you for your attention to this matter. Please be advised that violations of the Stormwater Permit may be subject to civil penalty assessments of up to S23,000.00 per day; per violation. Your above -mentioned response to this correspondence will be considered in this process. If you should have any questions, please do not hesitate to contact Steve Mauney at (336) 771-4969. Sincerely, Sieve W. Tedder Water Quality Regional Supervisor Attachments Cc: SWP-Central Files '\NISRO NPS Assistance and Compliance Oversight Keith Huff, Cit., of 1A7S Stormwater Division i4rCGA General Statutes - GS § 143-215.85. Required notice. htxp://utwv.ncaa.state.nc.tisl5tatutes/Ocnerai�itatuies/ri i 1V1LjUyaeCu._. § 143-215,85, Required notice. (a)Except as provided in G.S. 143-215.94E(al) and subsection (b) of this section, every person owning or having control over oil or other substances discharged in any circumstances other than pursuant to a rule adopted by the Commission, a regulation of the U. S. Environmental Protection .agency, or a permit required by G.S. 143-215.1 or the Federal Water Pollution Control Act, upon notice that such discharge has occurred, small immediately notify the Department, or any of its agents or employees, of the nature, location and time of the discharge and of the measures which are being taken or are proposed to be taker, to contain and remove the discharge. The anent or employee of the Department receiving the notification shall immediately notify the Secretary or such member or members of the permanent staff of the Department as the Secretary may designate. if the discharged substance of which the Department is notified is a pesticide regulated by the North Carolina Pesticide Board, the Department shall immediately inform the Chairman of the Pesticide Board. removal operations under this Article of substances identified as pesticides defined in G.S. 143-460 shall be coordinated in accordance with the Pesticide Emergency Plan adopted by the North CaroliLa Pesticide Board; provided that, in instances where entry of such hazardous substances into waters of the State is imminent, the Department may take such actions as are necessary to physically contain or divert such substance so as to prevent entry into the surface waters. (b) As used in this subsection, "petroleum" has the same meaning as in G.S. 143-215.94A. A person who owns or has control over petroleum that is discharged into the environment shall immediately tale :measures to collect and remove the discharge, report the discharge to the Department within 24 hours of the discharge, and begin to restore the area affected by the discharge in accordance with the requirements of this Article if the volume of the petroleum that is discharged is 25 gallons or more or if the petroleum causes a sheen on nearby surface '.rater or if the petroleum is discharged at a distance of 100 feet or !ess from any surface Slater body. If the volume of petroleum that is discharged is less than 25 gallons, the petroleum does not cause a sheen on nearby surface water, and the petroleum is discharged at a distance of more than 100 feet from all surface water bodies, the person who owns or has control over the _petroleum shall immediately take measures to collect and remove the discharge. if a discharge of less then 25 gallons of petroleum cannot be cleaned up within 24 hours of the discharge or if the discharge causes a sheen on nearby surface water, the person who owns or has control over the petroleum shall immediately notify the Department. (1973, c. 534, s. 1; c. 1262, s. 23; 1977, c. 771, s. 4; c. 852, s. 1; 1979, c. 535, ss. 16, 17; 1987, c. 827, ss_ 151, 194; 2000-54, s. 1.) 1 of 1 1/41/2005 11A3 ANI Permit: NCG030474 SOC: County: Forsyth Region; Winston-Salem Compliance Inspection Report Effective: 11101I07 Expiration: 10/31/12 Effective: Expiration: Contact Person: Michael A Carcieri Title: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): 24 hour contact name Michael A Carcieri Related Permits: � Inspection Date: 0110712v Entry Time: 01 00 PM Primary inspector: Max S Mauney Secondary Inspector(s): Certification: Owner: Lyndon Steel Company Facility: Lyndon Steel Company 1947 Union Cross Rd Winston Salem NC 27107 Phone: 336-785-0848 Exit Time: 02 30 PM Phone: 336-785-0848 Phone: 336-771-5000 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: Q Compliant ® Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit NCG0304A Owner - Facility: Lyndon Steel Company Inspection pate: 0110712009 Inspection type: ComplianCe Evaluation Reason for Visit: Routine Inspection Summary: Page: 2 Permit: NCG030474 Owner - Facility: Lyndon Steel Company Inspection Date: 01/07/2009 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? ® D D n # Does the Plan include a General Location (USGS) map? m D D D # Does the Plan include a "Narrative Description of Practices"? ® D ❑ D # Does the Plan include a detailed site map including outfall locations and drainage areas? D ® D D # Does the Plan include a list of significant spills occurring during the past 3 years? ®D D D # Has the facility evaluated feasible alternatives to current practices? ❑ ©D # Does the facility provide all necessary secondary containment? ® D D D # Does the Plan include a BMP summary? ® n D n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® D D n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® D n rl # Does the facility provide and document Employee Training? ®n n n # Does the Plan include a list of Responsible Party(s)? ® D D D # Is the Plan reviewed and updated annually? D M D D # Does the Plan include a Stormwater Facility Inspection Program? ® D n D Has the Stormwater Pollution Prevention Plan been implemented? M D D D Comment: The plan was updated in September 2007, but there is no documentation of a review of the plan in the last 2 years. A page could be added to the plan to show documentation that it was reviewed/updated annually. The site map does not include the listing of outfall #2 nor the drainage area that goes to it nor the amount of impervious area. The plan includes a feasibility study, but it is recommended that the study be updated to include an analysis of the method to continue doing all steel painting inside. Mr. Carcieri noted that ail painting is done inside now, but that if business changed they may need to resume painting outside. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ® D Q D Comment: The qualitative monitoring is done concurrently with the quantitative monitoring by R&A. Recent reports failed to use the numerical reporting system ( for clarity, floating solids or for suspended solids) as noted on the example form provided by DWQ This procedure should be changed on future qualitative inspections. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ® Cl D 0 # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? D n ® D Comment: The analytical monitoring has not been submitted to DWQ, but Mr. Carcieri was asked to send in the last 2 years of data. Page: 3 Permit: NCGO30474 Owner - Facility: Iyndon Steel Company Inspection Bate: 01/0712009 Inspection Type: Compliance Evaluation Reason for visit: Routine Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 6 0 0 n # Were all outfalls observed during the inspection? ®nnn # If the facility has representative outfall status, is it properly documented by the Division? 0 n ■ n # Has the facility evaluated all illicit (non stormwater) discharges? MOOD Comment: The site was evaluated on 3-1-07 for illicit non-stormwater discharges. Fart II. A. 7. (page 3 of 9) requires that the annual plan update, "include re -certification that the stormwater outfalls have been evaluated for the presence of non stormwater discharges." Page: 4