NCG030528_COMPLETE FILE - HISTORICAL_20150304

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ Z) 1 `J C�a-) 01
YYYYM M DD

•
Public Wod4
Department.
3
5tormwatulErosian and
5ediinentation Control Program
cry orvrr=o -Sz1an
P.Q. Bo. 2511
vc+insca�rSalcm; NC 27102
CiryUpk 311 (336.727-MM)
.Fax [phone]
F ,
evwucrnrnaw+rinr�nart.rom
March 4, 2015
Mrs. Christi ne-MAciaren
Human Recourses .
Winston Steel & Staii.. Co_
216 Junia-Ave-
Winston Salem, NC,27127
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 3_l, 2014
inspection of Winston'Steel LLC.
Winston _Steel_ LLC-has-provided d6cuinentatioh that;.verifies the successful
completion -of the;corrective,measures located in Part-4 —Required Actions
10 be completed by Facility, At this time;.Winston Steel LLC has no
outstanding: inspection:compliance items:to complete.
The,Stoririwatei Division reserves the rig}` to enter and inspect Winston
Steel LLC as often as necessary to determine:compliance-.wiih.perrnit
requirements_ of Win&on.Stecl's-NCG permit
Thank you -far -your continued support and implementation of the.'City of
Winston $Salem's Stormwater, Pirograzn. If you have any. questions, please
feel,free:to contact meat (336).747-6964.
Sincerely,
_ 444_t��
'Ladonta ."Jama1" Clark
i I St&n watd.Inspector
Phone: �33 6.747.6964
Cell: 336:4.16.2403
Fax: [phone].
l NISp 'D&-rE7
3(t3t Ls
1�11CLtp3OS2j9
Call 311 or 336-727.8000
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(W
Stormwater/Erosion_Control Division
Surface Water Re -inspection of V1Winstoh Steel LLC
Successfully.
Completed?
Part ]-Required Actionsfrom the July 30, 201 ins action Yes No
Notes
1) Has- Winston'Steel'LLG denoted on the general map that,
Winston Steel LLC discharges to the. (MS4)
✓
Municipal Separate Storm Sewer System and ultimately
dischar es into-Salem�Creek.
2) Has Winston .Steel LLC provided and updated the' signed
certification.statement,by the�responsible corporate officer in
.the SPPP?
3) Cdncerning.outfalls l; 2, 3, and 5,.has as Winston Steel LLC
✓
listed,the potential,pollutants that could'be discharged and their
0hysical Iocations on their -site.-map?
4) Regarding.outfalls 4, 6' and 7, has- Winston Steel LLC
updated the�SPPP with the,;proper documentation stating the
exern Lion ofarial Teal rri©riitorin -for outf ills 4,.,6; arid`-7,?
5) Has=Winston Sieel LLC updated<the City of Winston Salem,.
Stormwater:Divisiori's contact information to Winston Steel
LLC Spill Notification Eist?
6), Has Winston Steel, LLG updated and -signed the responsible
✓
section of.the'SPPP?
7) Concerning sampling Year.2 — Period-1 sample numbei'3
✓
(January 1, 2014 -June 30, 2014); has Winston:Steel"LI C
accomplished the tier I response for,exceeding the.'tier' 1
benchmarks?
8) With,refererice to the solverit inanage ent plan. has,
✓
A solvent management.
Winston Steel LLC supplied the end results?
plan is'requiied, and
documentation has been
provided to show
records.
,2

Part 2 — Required Actio�ts to be completed 6y Facility::'
L. None: Lyndon Steel Company LLC has -successful ly'completed all Required Actions to be
coipleted by the Facilityof ihe..July 31 j 20,14 inspection.
Sioature of Storrnwater Inspector:
Title: Stormwater lns ectoi
`3

White, Sue
From: LaDonta Clark <[e-mail]>
Sent: Wednesday, March 04, 2015 12:03 PM
To: 'cmaclaren@lyndonsteel, com'
Cc: Keith Huff, John Spainhour, White, Sue
Subject: Completed close out letters for Winston Steel LLC, and Lyndon Steel LLC
Attachments: Lydon Steel close out letter.pdf; Winston Steel Close out letter.pdf
Dear Mrs. Maclaren,
This letter will serve as official notification that Winston Steel LLC and Lyndon Steel LLC have successfully completed Part
1, Required Actions to be completed by Facility, of the July 302h and 31" , 2014 inspection reports. A copy of my finished
re -inspection forms have been enclosed for your documentary purposes. At this juncture, Winston Steel LLC and Lyndon
Steel LLC have no outstanding inspection compliance items to complete. Hard copies have been placed in the mail to
your attention. I encourage you to contact me with any questions or comments.
Ladonta Clark Uarrial)
Stormwater Inspector
City of Winston Salem
Stormwater/F,rosion and
Sedimentation Control Program
Phone: [phone]
Cell: 336.416.2403
Fax: [phone]
City of Winston-Salem
ONE TEAM
Committed to Exceflence
All a -mails including attachments sent to and from this address are subject to being released to the media and the public in accordance with the North Carolina
Public Records Law.

Taylor -Smith, Aana
From: LaDonta Clark <ladontac@cityofws_org>
Sent: Wednesday, August 20, 2014 2:14 PM
To: [e-mail]
Cc: John Spainhour; Keith Huff; Taylor -Smith, Aana; [e-mail]
Subject: Winston Steel LLC Inspection Package Completed
Attachments: Winston Steel LLC Inspection Package Completed.pdf
Good afternoon Mrs. Maclaren,
As per our previous conversation, I am furnishing an electronic copy of my completed inspection package. A hard copy
has been placed in the mail to your attention. I encourage you to contact me with any questions or comments.
Thank you for your time and professional courtesy during our inspection,
Ladonta Clark uamal)
Stonnwater .Inspector
City of Winston Salem
Stornnwater/Erosion and
SediMentation Control Program
Phone: [phone]
CeLl: 336.416.2403
Fax: 336,748.3173
City of Winston-Salem
ONE TEAM
Committed to ExCellence
All a -mails including attachments sent to and from this address are subject to being released to the media and the public in accordance with the North Carolina
Public Records Law.

0
mnstonsmem
Public Works
Department
StormwaterlEtmion and
Sedimentation Control Program
City of WmaaaSdem
P.O. Boa 2511
Wmimn-Sal., NC 27102
City" 311 (336.727,8000)
F2x 336,7483173
varcam
August 20, 2014
Mrs. Christine Maclaren
Human Recourses
Winston Steel 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 31; 2014 inspection of
Winston Steel 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 9148 that Winston Steel LLC
must complete. Please provide documentation that verifies Winston Steel LLC
successful completion of the corrective measures to me by November 20, 2014.
The Stormwater Division reserves the right to enter and inspect Winston Steel LLC
as often as necessary to determine compliance with permit requirements of
NCG030474.
T'han_k you for your continued support and implemeritation of the City of Winston-
Salem's Stormwater Program. If you have any questions, please feel free to contact
me at [phone].
Sincerely,
Ladonta Clark
Stormwater Inspector
Phone: [phone]
Cell: 336.416.2403
Fax: [phone]
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cityEi nkC&6tyofws.org

ufJ
Stormwater/Erosion Control Division
Surface Water Inspection for Industrial Sites
G rai Information
A) Official Company Name: Winston Steel LLC
B) Physical Address: 216 Junia Ave, Winston-Salem, NC 27127
C) Telephone Number: [phone] Office
D) Mailing Address, if different from above address: 1947 Union Cross Rd, Winston-Salem, N.C. 27107
E) Authorized contacts to represent company in environmental regulatory issues:
Primary contact: Mrs. Christine Maclaren
Title: Human Recourses
Contact number(s): Office (336)-785-0848 ext. 218 Cell (336)-972-0436
Email address: [e-mail]
Secondary contact: Dave Coiling
Title: Shop Supervisor
Contact-number(s): (336)-345-1676 Cell Phone
Email address:[e-mail]
F) SIC Code Number of business: Fabricating of Metal Products (SIC 34)
G) NC Stormwater NPDES Permit Number: NCGO30474
Permit Category: (General) Fabricating of Metal Products
H) Any other control authority permit(s) (air quality control, wastewater, hazardous waste) & number(s):
N/A
17 Brief description of industrial activities that occur on -site: The fabrication of steel products that are sold
for commercial purposes.
1) Ultimate Receiving Waters: Salem Creek (Middle Fork Muddy Creek)
TMDL stream ®Yes ONo
Part I - Stormwater Controls
1. Best Management Practices
a. List the nonstructural controls employed by the tacility:
1. The equipment shed is covered to protect items such as, gas cans, weed eaters, lawnmowers, and
other machines.
2. A settling tank has been placed under the gas products behind the building near an AST tank

b. Are the BMPs reasonable & appropriate for the facility? MYes ONo
Spill kits are placed in the equipment shed.
c. Are BMPs installed correctly, maintained, and effective operating condition? ®Yes ONo
Both AST tanks are properly maintained and operating.
2. Provide a brief description of other controls that manage/preVentiminin-rn ize stormwater noff
(e.g., erosion and sediment controls, inlet protection/control at storm drains, diversion structures):
All drains have a grate over them to prevent erosion and sediment.
Part 2 — Miscellaneous
1. Any evidence of discharge to receiving waters/MS4? (e.g.: stormwater runoff, dry weather discharge, co -
mingling of process wastewater): Wes ONo
Winston Steel LLC discharges to the (MS4) Municipal Separate Storm Sewer System and
ultimately discharges into Salem Creek.
2) Do the stormwater outfalls on -site correspond with those listed on the site reap and in SPPP?
®Yes ❑No
Outfalls t, 2, 3; and 5 are missing the potential pollutants that could be discharged and
their physical locations. Since the stormwater discharge outfalls 4, 6, and 7 no longer
require analytical monitoring, please update the SPPP with the correct status of those
outfalls.

3) Summary of Storrnwater Discharge Outfalls.
SDO Identification
Potential Pollutants that
Physical Location
Latitude and Longitude
could be discharged
OutfaH 001
36.0714,-8023529
Outfall 002
6?
36.07148,-80.23614
Out -fall 003
36.04157,-80.1409
Outfa11004
7 No more Analytical
? No more Analytical
36.04164,-8014107
Sampling
Sam lin `
OutfaI1005
J,
36.04176,-8014117
Outfafl 006
No more Analytical
—
7 No more Analytical
36.04171;-8014071
am lin [—
Sampling[
Sampling
Outfa11007
? No more Analytical
— _
------
? No more Analytical
36,04176,-$014100
am lin r--
Sampling,
Sam lino
Site Overview
iPart 3 iSPPP Review (can be completed in office)
Yes No Notes
Is there a SPPP?
✓
Does SPPP include a certification statement by the responsible
✓
No signature or dates
corporate officer?
Does the general map depict the facility's location on a USGS quad
✓
m ore trivalent map)_with receivin waters or MS4 listed?
Identification of impaired waters or watershed (if applicable)?
✓
Salem Creek (Middle fork
Muddy Creek
Narrative'Description of these_ industrial Activities:
Storage Practices
Unloading/Loading Activities
✓
Outdoor Processes
✓
Particulate Generating/Control Processes
✓
Waste Disposal
✓
Does site map denote drainage items: flow directions, boundaries, %
✓
Several SDO'S are missing
impervious, and structures? Also includes SDOs, industrial activity
the physical location and the
areas, and site topography?
potential pollutants that
could be discharged.
A list of major spills that have occurred within the past three years
✓
with corrective actions to prevent futurespills)?
A signed, annual certification that the. facility has been tested for non-
✓
FT
stormwater discharges from the site?
Comments:
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 Buff, Stormwater Director [phone] = landline (336) 406-
3332 = cell phone number. Mr. Huffs email address is keithh1(a7)Sjtyofws.org 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 tanXs, stored materials, release records)
BNT Summary (listing of site structuralfnonstructural practices)
SPRP & Procedures (identified, responsible personnel w/ signatures & dated)
PM & GH (inspection of material handling areas & regular cleaning schedules)
Facility Inspections (biannual inspections of facility and all storrnwater systems)
Employee Training (annual basis for staff who perform SRtP and PM functions)
Responsible Party (specific position(s)dcvclopin& implementing, & revising SPPP)
Amendment &. Annual Update (of major spills, nonsw flows, nlvlPs, sampling data
Last found training log was in 4-26-
2014
No signature or dates.
Does SPPP contain completed'routine inspection reports/records
regarding reportable implementation of the nine baseline controls
i.e. SPPP Implementation)?
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 sam&ng events 60 days apart? (EXCE-PTRON: Ter 2 & 3 responses)
✓
Is analytical monitoring complete (including schedule) for each
✓
No discharge characteristics
SDO? (EXCEPTIom Pos)
for Copper and Zinc 2013
and 2012.
✓
(RNA) 1-7-2013 (Sampled in
2012) lead levels were over
benchmark for outfalls 1, 5,
and 7. (RNA date) 7-14-
Any exceedences of pollutant parameters when compared against the
2014 lead levels were over
permit benchmark values?
for outfalls 1,6,7,4,5,8
Copper levels were over for
outfalls 1,6,7, and 8
TSS levels were over for
outfalls for 1,6,7,5, and S.
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?
Are monitoring events 60 days art? (EXCUTION: Tier 2 & 3 responses)
Any observable, excessive amounts of pollutant indicators in
stormwater discharge at SDOs?

Part4 — Required Actions to be completed by Facility'
r-
1. Please denote on the general map that, Winston Steel LLC discharges to the (MS4)
Municipal Separate Storm Sewer System and ultimately discharges into Salem Creek.
2. Please provide and update the signed certification statement by the responsible
corporate officer in the SPPP.
3. Concerning outfalls 1, 2, 3, and 5, please list the potential pollutants that could be
discharged and their physical locations.
4. Regarding outfalls 4, 6, and 71) please update the SPPP with the proper documentation
stating the exemption of analytical monitoring for outfalls 4, 6, and 7.
5. Please update the City of Winston Salem, Stormwater Division's contact information
to Winston Steel LLC Spill Notification List.
6. Update and sign the responsible party section of the SPPP.
7. Concerning sampling Year 2 — Period-1 sample number 3 (January 1, 2014 -June 30,
2014) , please accomplish the tier i response for exceeding the tier 1 benchmarks
and provide a copy of the tier 1 response to me.
8. With reference to the "solvent management plan of Winston Steel LLC, please supply
the end results of the status once completed. Also, update the SPPP with the final
status of the solvent management plan.
Company Representative(s) that participated in inspection: Mrs. Christine Maclaren
Title(s): Human Resources Manger
Start of Inspection: 9:00am
Completion of Inspection: 11:00am
Date: 7/31 i2014
Signature of Stor mwater Inspector:
Title: Stormwater Inspector

Compliance Inspection Report
Permit: NCG030528 Effective: 11/01/12 Expiration: 10/31/11 Owner: Winston Steel LLC
SOC: Effective: Expiration: Facility: Winston Steel LLC
County: Forsyth 216 Junia Ave
Region: Winston-Salem
Winston Salem NC 27127
Contact Person: Christine Maclaren Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representatives):
Related Permits:
Inspection Date: 07/3112014 Entry lime: 09:00AM
Primary Inspector. Aans Taylor -Smith
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 11:00AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation.
Permit Inspection Type: Metal Fabrication Siormwetor Dischmige COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030528 Owner - Facility:winston steel LLC
Inspection Date: 0713112014 inspection Type :Compliance Evaluation Reason for ViS[tl Routine
Inspection Summary:
Inspections conducted by local program. Please refer to letter sent by l_aDonta Clark.
Page: 2

Permit: NCG030528 Owner - Facility: Winston Steel LLC
Inspection Data: 07I3112014 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?
# Goes 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 Plain 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:
Qualitative Monitoring
Has the facility conducted its Oualitative Monitoring semi-annually?
Comment:
Analytical Monitorina
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfaUs 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, ROS granted July 2014
Reason for Visit: Routine
Yes No NA NE
■ ❑ ❑ ❑
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■❑❑❑
®❑❑❑
■❑❑❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
®❑❑❑
®❑❑❑
013013
■❑❑❑
■❑❑❑
Yes No NA NE
N ❑ ❑ ❑
Yes Na NA NE
0❑❑❑
❑❑■❑
Yes No NA NE
® ❑ ❑ ❑
Page: 3

NCD
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
10 July 2014
Christine MacLaren
Winston Steel & Stair
1947 Union Cross Road
Winston-Salem, INC 27107
Subject: NPDES Stormwater Permit No. NCG030528
Representative Outfall Status Request
Winston Steel & Stair — 216 Junia Ave.
Forsyth County
Dear Ms. MacLaren:
John E. Skvarla, III
Secretary
The Winston-Salem Regional Office staff has reviewed your request received 30 June 2014 for
determination that Outfolls 1, Z and 3 be granted representative outfall status for Outfolls 4, 6, and 7 at
the Winston Steel & Stair site located at 216 Junia Avenue in Winston-Salem, North Carolina. Based on
Aana Taylor -Smith's site inspection on 10 July 2014, we are approving this request. In accordance with
40 CFR §122.21(g)(7), you are authorized to sample outfalls 1, z, and 3 as the representative outfalls.
Outfall 5 must continue to be sampled in addition to Dutfalls 1, 2, and 3. This approval is effective with
the next sampling event. However, this approval is contingent on the following requirements:
(1) All outfalls, regardless of representative status, must have a cleared path and the right of way to
the outfall must be properly maintained.
(2) The permit still requires that. Qualitative Monitoring be performed at all Stormwater Discharge
Outfalls, regardless of representative status.
In addition, please remember that any actions you initiate in response to benchmark exceedences as
directed in the tiered response provisions of your permit must address all drainage areas represented by
Outfalls 4, 6, and 7, where appropriate. The site drains to Salem Creek, which is currently classified as
Class C waters, in the Yadkin Pee -Dee River Basin.
Please append this letter to your Stormwater Pollution Prevention Plan or permit to document that
representative outfall status has been approved. If changes in drainage areas, structures, processes,
storage practices, or other activities occur that significantly alter the basis of this approval,
representative outfall status may no longer be valid. You should either resume sampling at all storm
water discharge outfalls, or reapply to this office for representative outfall status based on updated
information.
Division of Energy, Mineral, and Land Resources
Land Quality Section • Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, NC 27107 • Phone: [phone] / FAX: [phone]

Winston Steel & Stair
07/10/2014
Page 2 of 2
If you have any questions or concerns concerning this letter and the attached report, please contact Ms.
Taylor -Smith at [phone] or at [e-mail].
Sincerely,
Matthew E. Gantt, PE
Regional Engineer
Land Quality Section
cc: LQ — WSRO
Stormwater Permitting Unit
Central Files

WINSTON STEEL & STAIR
ar=ca:lvso
I947 UNION CROSS ROAD N.C.Dept. of EN
R
WINSTON-SALEM, NORTH CAROLINA 27107 steel♦
PHONE: [phone] FAX: [phone] ♦' ��� J 9 O �f11�
WEB SITE: %ni-wivndonsteel.com 01
Winston-Salem
Regional office
NC DENR Division of Water Quality
Surface Water Protection Section
585 Waughtown Street
Winston-Salem, NC 27107
June 26, 2014
Re: Winston Steel, LLC Request for Representative Outfall Status
Permit No. NCG030528. 216 Junia Ave, Winston-Salem, NC
Dear Sir or Madam:
Enclosed please find a Request for Representative Outfall Status for Winston Steel, LLC
This request is being submitted as suggested by an NCDENR inspector. The site is
currently sampling at eight outfalls. We are requesting to reduce the number of outfalls
tested to four. As discussed in the attached application and site diagrams, we have
,/determined that the site can be broken down into four separate areas: raw material
storage (area A), unloading and parking (area B), roof drainage (area C) and finished
product storage (area D). These areas are sampled at the following outfalls: area A at
outfall 005, area B at outfall 002, area C at outfall 003 and area D at outfall 001. The
remaining four outfalls, 004, 006, 007 and 008 are represented by those listed above
Outfalls 006 and 007 both receive roof runoff which is represented by outfall 003. Outfall
006 also receives a small portion of the runoff from the finished goods storage 1 loading
area which is represented by outfall 001. Outfall 007 also receives a small portioi i� of the
unloading and parking area which is represented by outfall 002. Allowing outfalls 006
and 007 to be represented will reduce the possibility of inaccurate results from excess
water from the street as well as any pollutants that may be left on the roadway that did
not originate at the site.
Outfalls 003, 004 and 008 receive roof runoff and runoff from a small portion of the
southern boundary of the property. We request that outfall 003 be allowed to represent
outfall 004 and 008 in future sampling.
If you have any questions regarding this request please contact me at [phone],
Sincerely,
Winston Steel, LLC
Christine MacLaren
Human Resources Manager
enclosures

'77"awA
NCDENR
N�� C�_ —�
E-d+HE Mo N�RE' RCE9
FOR AGENCY USE ONLY
Dale Received
Division of Water Quality / Surface Water Protection Year Mond, Day
National Pollutant Discharge Elimination System
REPRESENTATIVE OUTFALL STATUS (ROS)
REQUEST FORM
if o facility is required to sample multiple discharge locations with very similar storm water discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DWQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
if Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DWQ
approval. The approval letter from DWQ must be kept on site with the facility's Storm water Pollution
Prevention Plan. The facility must notify DWQ in writing if any changes affect representative status.
For questions, please contact the DWQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
;.S , N. C,] G_ 0 1 3 1 0 J 5 1 2 18
2) Facility Information:
Owner/Facility Name Winston Steel LLC
Facility Contact Christine MacLaren, Human Resources Manager
Street Address 216 Junia Avenue
City Winston Salem State NC ZIP Code 27107
County Forsyth E-mail Address hr winstonsteel.com
Telephone No. (336 785-6151 Fax: ( 336 788-8885
3) List the representative outfalls) information (attach additional sheets if necessary):
Outfall(s) I and 3 is representative of Outfall(s) 6
Outfalls' drainage areas have the same or similar activities? Xo Yes u No
Outfalls' drainage areas contain the same or similar materials? Xo Yes a No
Outfalls have similar monitoring results? Xq Yes ❑ No ❑ No data*
Outfall(s) 2 and 3 is representative of Outfall(s) 7
Outfalls' drainage areas have the same or similar activities? Xo Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? X❑ Yes ❑ No
Outfalls have similar monitoring results? (Outfall4 date under BM) Xo Yes ❑ No o No data*
(Outfall 7 has exhibited higher analytical values believed to be a result of off -site contaminants.)
Outfall(s) 3 is representative of Outfall(s) 4 and 8
Outfalls' drainage areas have the same or similar activities? X❑ Yes o No
Outfalls' drainage areas contain the same or similar materials? Xa Yes ❑ No
Outfalls have similar monitoring results? X❑ Yes o No l7 No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 4
SWU-ROS-2009 Last revised 12/3012009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
0utfall 1 collects water from the finished Foods and loading area on the west side of the site along with
water from the dumpster area. _Outfall 2 collects_ drainage from the parking and raw material storage area
on the east side of the site. Outfall 3 collects storm water from the roof along the back of the site.
Outfall 6 and 7 collect water from the front side of the roof and small portions of the parking lot and storage
areas. Outfalls 6 and 7 are represented by the roof collection of Outfall 3 and the gravel areas of Outfall 1
and 2.
Outfalls 4 and 8 collect roof water from the back side of the roof. These outfafls are represented by Outfall
3.
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars ($10,000).
I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DWQ in writing if any changes to the facility or its operations take
place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must resume
monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such informations iis true, cccomplete, and accurate.
Printed Name of PerW Signing: 1.,1�� JT► l�1� ! I jQ�i r��
Title:
r
(Signature of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to approval by the
NCDENR Regional Office. The Regional Office may inspect your facility for compliance with the
conditions of the permit prior to that approval.
Final Checklist for Roy Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 4
SWU-ROS-2009 Last revised 12/30/2009

= Finished Material
------ = Raw Storage (steel)
= 35% impervious
(C=0.75)
= Diesel & Kerosene Tanks
■ = Dumpster Disposal Area
❑ = Outflow (SDO)
® = Containment Pallet
(55/gal. Paint Drums)
—4 = Direction of
Stormwater Flow
aao��.8�da
Y �/ri J7V r •J
t inch = US fW
The numbers on the aerial map indicate,
elevations above sea level

94
42 841
$1
V
841
AMN
4 WW� AMM N
f
y
iiii,1111W Mort
= Finished Material
= Raw Storage (steel)
35% impervious
(C--0.75)
Diesel & Kerosene Tanks
■ = Dumpster Disposal Area
❑ = outflow (SDO)
® = Containment Pellet
(551gal. Paint Drums)
- 4 = Direction of
Stonnwater Flow
Rt
840
a4°=
t inch = 34.5 foot
The numbers on the aerial map indicate.
elevations above sea level

Finished Material
= Raw Storage (steel)
_ 35% impervious
(C=0.75)
= Diesel & Kerosene Tanks
d U B40 4
i 1 I n RAG
Dumpster Disposal Area
== Outflow (SDO)
= Containment Pallet
(551gal. Paint Drums)
Direction of
Stormwater Flow
on 106 it
t inch = 34.5 feet
!' The numbers on the aerial reap indicates ground
elevations above sea level

= Finished Material
= Raw Storage (steel)
_ -- 35% impervious
(C=0.75)
= Diesel & Kerosene Tanks
Dumpster Disposal Area
Outflow (SDO)
= Containment Pallet
(551gal. Paint Drums)
--� = Direction of
Stormwater Flow
g &L8
1_1*00
��- -840
nn 106 tt
1 inch = 34.5 feet
The numbers on the aerial map indicates ground
elevations above sea level

Sampling Results Under Current Permit
June 24, 2013 Outfall 1 Outfall 2 Outfall 3 Outfall 4 Outfall 5 Outfall 6 Outfall 7 Outfall 8
Total Susp Solids
<1.0
18
<1.0
53
12
13
11
68
(mg/L)
Oil & Grease (mg/L)
<5.0
<5.0
<5.0
<5
<5.0
<5.0
<5.0
<5.0
Total Lead
<.005
<.005
<.005
<.005
<.005
<.005
<,005
<.005
(mg/L)
pH
6.61
6.52
6.54 1
6.73
6.62
6.89
6.51
6.51
Temp
22.9
21.7
23
23.2
22.7
23.4
22.1
22.6
(°C)
Date of Event:
6/6/2013
Rainfall Total:
2.18 in
Duration of Event:
17 hours
December 19. 2013 Outfall 1 0utfa112 Outfall 3 Outfall 4 0utfa115 Outfall 6 Outfall 7 Outfall 8
Total Susp Solids
(mg/L)
13
584
202
<1.0
76
216
296
34
Oil & Grease (mg/L)
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
Total Lead
<.005
0.123
0.277
<,005
0.763
0.018
0.103
0.013
(mg/L)
pH
7.46
7.92
7.48
7.76
7.86
7.36
7.96
7.96
Temp
5.2
6.9
5.3
5.4
10.3
5.6
7.1
8.2
Date of Event:
12/9/2013
Rainfall Total:
0.32 in
Duration of Event:
6 hr 45 min

RESEARCh & ANA1yT9CA1
now
W. V LAbORATOREES, INC.
Analytical/Process Consultations
�=� =YJ
December 19, 2013
Winston Steel LLC
1947 Union Crass Road
Winston-Salem, NC 27107
Attention: Mr. Mike Carcieri
Chemical Analysis for Stormwater Sampling identified as Winston Steel (Oulfalls 001-008), collected 09 December 2013
IIIItpf,,
NO#34
•,•RIB �/f UtANp���++
1.
Project Number: NIA
NPDES4: NCG030000
Sample
Identification
RAL
Sample
Number
Sampling
Date
Sampling
Time
Total
Suspended
Solids
(mg(L)
Oil
&
Grease
(mglL)
Total
Lead
(mg/L)
pH
(SU)
Temperature
(°C)
Date
Analyzed
005
774110
12/09/13
0920
76.0
<5.0
0.763
7.86
10.3
12/12 & 12113
008
774111
12/09/13
0929
34.0
<5.0
0.013
7.96
8.2
12/12 & 12/13
007
774112
12/09/13
0940
296
<5.0
0.103
7.96
7.1
12/12 & 12113
002
7741 13
12/09/13
0948
584
<5.0
0.123
7.92
6.9
12/12 & 12113
004
774114
12/09/13
0959
<1.0
<5.0
<0.005
7.76
5.4
12/12 & 12/13
003
774115
12/09/13
1008
202
<5.0
0.277
7.48
5.3
12/12 & 12/13
006
774116
12/09/13
1017
216
<5.0
0.018
7.36
5.6
12112 & 12/13
OOl
7741117
1
12/09113
1025
13.0
<5.0
<0.005
7.46
5.2
12/12 & 12/13
j
Anaiyst: NM, YJ, SK & JC
mgll, - milligrams per Liter - parts per million (1111M)
SU = Standard Units
<= less than or Below Quanlitation Limit (13QL)
°C — Dcgrccs Ccicius

RESEARCh & ANA1yTICAL
F. i. LAbORATORIES� INC.
Analytical/Process Consultalions
December 19, 2013
Winston Steel LLC
1947 Union Cross Road
Winston-Salem, NC 27107
Attention: Mr. Mike Carcieri
Chemical Analysis for Stormwater Sampling identified as Outfalls 001-008 at Winston Steel LLC- Winston-Salem, NC
1. 1 Project Number: N/A
Total Suspended Solids
(I'SS)
Oil & Grease
Lead
Sample Number
Sample Date
Sample Time
Rainfall 0.32 in.
Event Duration 6 hrs. 45 min.
Results of Visual Monitoring of Stormwaler
at Winston Steel - Winston-Salem, NC
11. 1 Project Number: NIA
Stormwater
Discharge
Charteristics Fre uenc
Color Semi -Annual
Odor Semi -Annual
Clarity
Semi -Annual
Floating Solids
Semi -Annual
Suspended Solids
Semi -Annual
Foam
Semi -Annual
Oil Sheen
Semi -Annual
Other obvious
on idicators of
slormwnter pollution
NPDES #NCGI130000
Quantilation
Limit 001
1.0 13.0
5.0 <5.0
0.005 <0.005
0.1 Std. Units 7.46
774117
12/09/13
1025
002
{me11
003 '
f-E1L1
004
(me11
005
m !L
006
(melt)
007
!LELILI
008
(mQlL1
584
202
<L0
76.0
216
296
34.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
0.123
0.277
1 <0.005
1 0.763
1 0.018
1 0.103
1 0.013
7.92
7.48
1 7.76
1 7.86
1 7.36
1 7.96
1 7.96
774113
774115
774114
774110
774116
774112
774111
12/09/13
12/09/13
12/09/13
1
12/09/13
1
12/09/13
12109/ 13
12/09/13
0948
1008
0959
0920
1017
0940
0929
11 Identified as Outfall 001 & 002
DES #NCG030000
Monitoring
Location
001
Monitoring
Location
002
Monitoring
Location
003
Monitoring
Location
004
Monitoring
Location
005
Monitoring
Location
006
Monitoring
Location
007
Monitoring
Location
008
Clear
Medium Brown
tight Orange
Clear
Light Brown
Light Orange
Medium Brown
Light Brown
None
None
None
None
None
None
None
None
Clear
Turbid
SL, Turbid
Clear
SL. Turbid
SL. Turbid
'Turbid
SL. "Turbid
None
None
None
None
None
None
None
None
None
Moderate
Moderate
None
Moderate
Moderate
Moderate
Moderate
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
Nate
None
None
None
None
None
None
Cul-off
Concentration
m L
100
30
0.033
6.0 - 9.0
Monitoring
Type
Visual
Visual
Visual
Visual
Visual
Visual
Visual
ing/L = milligrams per Uter — parts per million (PPm) BQL — Below Quantitalion Limits <= less than or Helow Quantitation Limit ([SQL)

STmmWATk 11 DISCHARGE OUTFALL (SDO)
MONITORING REPORT
GENERAL PERMIT NO: NCG030000 _
CERTIFICATE OF COVERAGE NO. NCG a2lo J Z�3
FACILITY NAME Winston Steel LLC
PERSON COLLECTING SAMPLES) Neal Msl)uffic (RAL)
CERTIFIED LABORATORY(S) R & A Lahoratoiies, Ine, Lab d 34
Lab #
SAMPLES COLLECTED DURING CALENDAR YEAR; 2013
(all samples collected during a calendar year, shall be reported no later
than January 31 of the following year)
COUNTY Forsyth
PHONE NO.
(SIGNATURE OF PERMITT:E OR DMS1G iE)
By this signature, i certify that this report is accurate and
complete to the hest of my knowledge.
Part A. Specific Monitoring Regnirements for stormwmer discharges from secondary containment structures associated with Petroleum Bulk Stations and Terminals and slormwafer
discharges from Oil Water Separators
Outfail
No.
Date
Sample
Collected
50050
00556
00545
01051
46000
00400
Total
Flow
Oil and
Grease
Total
Suspended
Solids
Lead, Total
Phenols Z
pI i
mo/dd/yr
MG
mg/l
mg/1
mg/1
mg/l
unit
001
12/09/13
0.040
<5.0
13.0
<0.005
7.46
002
12109/13
0,040
<5.0
584
0.123
7.92
003
12/09/13
0,040
<5.0
202
0.277
7.48
004
12/09/13
0.040
<5.0
<L0
<0.005
7.76
005
12/09/13
0.040
<5.0
76.0
0.763
7-86
006
12/09/13
0,040
<5.0
216
0.018
736
007
12/09/13
0.040
<5.0
296
0.103
7.96
008
12/09/13
0.040
<5.0
34.0
0.013
7.96
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yes X no
(if yes, complete Part 13)
Part B: Vehicle Maintenance Activity Monitoring Requirements
Pen A dogs nui apply. This faciliry dins nor discharge
siarmwo-ie� fromsecondary eonrainm��� *+�++ewrn of
oiVw Ier separators,
Outfall
No.
Date
Sample
Collected
50050
00556
01051
38260
00545
00400
Total
Flow
Oil and
Grease
Lead, Total
Recoverablet
Detergents
(MBAS)Z
Total
Suspended
Solids
pl-I
New Motor
Oil Usage
mo/dd/ r
MG
m l
u 1
m l
m l
unit
al/mo
STORM EVENT CHARACTERISTICS:
Date 12/9/2013
Total Event Precipitation (inches): 0.32
Event duration (hours): 6 hrs. 45 min.
(if more than one storm event was sampled)
Hate
Total Event Precipitation (inches): NIA
Event duration (hours): N/A
Mail Original and one copy to:
Atin: Central Files
DE14NR
Division of Environmental Mgt.
P.O, Box 29535
Raleigh, NC 27626-0535
Form MR-18
Page I of 2

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit hM://portal.incdenr.orgLweb/wq/ws/su/npdessw#tab-4
Permit No.: NCG030000
or Certificate of CoveralN/C/G () 30 152JO
Facility Name: Winston Steel
County: Forsyth Phone No. 0
Inspector: Neal McDuffie (RAL)
Hate of Inspection: 12/09/13
Time of Inspection: 1025
Total Event Precipitation (inches):
0.32
Was this a "Representative Storm Event" as defined by the permit?
(See information before.)
dyes a No
Please verb whether Qualitative Monitoring must be performed during a "representative storm event or "measureable storm
event" (requirements vary, depending on the permit.)
itative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
esentative storm event" or during a "measurable storm event." However, some permits do not have this requirement
refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
"measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local D WQ Regional Office.
By this signature, i certify that this
(Signature of Permitee or Designee)
is accurate and complete to the best of my knowledge:
S WU-242-020T45

1. Ouitfall Description
Outfall No. 001 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Clear
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
1I j 2 3 4 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
1 is no solids and 5 is the surface covered with floating solids:
1 2 3 4 5
(. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
1 2 3 4 5
7. Is there any foam in the stormwater discharge? Yes No
S. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there any evidence of errosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

by .•., ee,�,
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit hrm:llportal.nedenr.orWwebtwg/ws/su/npdessw#tab-4
Permit No.: NCG030000
Facility Name: Winston Steel
or Certificate of Covera�N/C/G
County: Forsyth Phone No. 'L5Q % 8 F (A ,�—
Inspector: Neal McDuffie (RAL)
Date of Inspection: 12/09/13
Time of Inspection: 0948
Total Event Precipitation (inches):
0.32
Was this a "Representative Storm Event" as defined by the permit".
(See information below.)
c es a No
Please verify whether Qualitative Monitoring must be performed during a "representative storm evert or "areasureable storm
event" (requirements vary, depending on the permit,)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred A single storm event may contain up to
10 consecutive hours of no precipitation.
"measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local DWQ Regional Office.
I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
SWU-242-020705

1. Outfall Description
Outfall No. 002 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area: Medium Brown
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: None
3. Odor: Describe any distinct colors that the discharge may have (Le., smells strongly of oil, weak chlorine odor,etc.)
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
1 2 3 1 4 1 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
I is no solids and 5 is the surface covered with floating solids:
1...1 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
1 2 4
7. Is there any foam in the stormwater discharge?
S. Is there an oil sheen in the stormwater discharge?
9. Is there any evidence of errosion or deposition at the outfall?
10.Other Obvious Indicators of Stormwater Pollution:
List and describe
5
Yes No
Yes No
Yes Na
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report .
For guidance on filling out this form, ptease visit h p:i/portal.ncdenr.orgfweb/wq/wsisu/ni)dessw#tab-4
Permit No.: NCG030000- or Certificate of Covera€N/C/G
Facility Name: Winston Steel
County: Forsyth Phone No.
Inspector: Neal McDuffie (RAL)
Date of inspection: . 12/09/13
Time of Inspection
1008
Total Event Precipitation (inches): 0.32
Was this a "Representative Storm Event" as defined by the permit?
(See information below.)
/yes o No
Please verify whether Qualitative Monitoring must be performed during a 'representative storm event or "measureable storm
event" (requirements vary, depending on the permit.)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event rn=uring greater thap- 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation -
A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must b
able to document that a shorter
approval #tom the local D WQ Regional Office.
this si ature I certify th this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
sv<v-242-020703

1. Outfall Description
Outfall No. 003 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur"within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Light Orange
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
1 3 4 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
I is no solids and 5 is the surface covered with floating solids:
0 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
1 2 4
7. is there any foam in the stormwater discharge?
8. Is there an oil sheen in the stormwater discharge?
9. is there any evidence of errosion or deposition at the outfall?
10. Other Obvious Indicators of Stormwater Pollution:
Lest and
5
Yes No
Yes No
Yes No
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant finther investigation,

Stormwater Discharge Qutfall (SDQ)
Qualitative Monitoring Report
For guidance on_f lling out this farm, please visit hgg://portal.ncdenr.org/web/wq/ws/suJnlpdessw#tab-4
Permit No.: NCG030000 or Certificate of CoveraiN/C/G
Facility Name: Winston Steel
County: Forsyth Phone Na. / )
Inspector: Neal McDuflie (RAL)
Date of Inspection: 12/09/13
Time of Inspection: 0959
Total Event Precipitation (inches):
0.32
Was this a "Representative Storm Event" as defined by the permit?
(See information below.)
dyes ❑ No
Please verb whether Qualitative Monitoring must be performed during a "representative storm event or "measureable storm
event" (requirements vary, depending on the permit.)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which ne storm--ver:t measuring greater than 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
A "measurable storm event" is a storm event that results in on actual discharge from the permitted site outfwl. The previous
measurable storm event must h
able to document that a shorter
approval from the local DWQ Regional Office.
By this �ature� l�c�i� �t this report Is accurate d complete to the best of my knowledge:
(Signature of Permitee or Designee) j` -t�j✓4�n
S W u-242-020705

1. Outfall Description
Outfall No. 004 Structure (pipe, ditch, etc.) Storm Gutter
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: None
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where I is clear and 5 is very cloudy:
2 3 4 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
I is no solids and 5 is the surface covered with floating solids:
1.� 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
0 2 3 4 5
7. is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. is there any evidence of errosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit hM-//i3ortal.nedenr.org/web/wq/ws/su/npdessw#tab-4
Permit No.: NCG030000 or Certificate of CoveraN/C/G
Facility Name: Winston Steel
County: Forsyth Phone No.
Inspector: Neal McDuffie (RAL)
Date of Inspection: 12/09/13
Time of Inspection:
0920
Total Event Precipitation (inches):
0.32
Was this a "Representative Storm Event" as defined by the permit?
(See
information below.)
o No
Please verify whether Qualitative Monitoring must be performed during a "representative storm event or "measureable storm
event" (requirements vary, depending on the permit.)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable,
A "representative storm event" is a storm event that measures greater than 0-1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local D WQ Regional Office.
that this Feport is accurate and f pmplete to the best of my knowledge:
(Signature of Permitee or Designee)
S WU-242-020705

1. Outfall Description
Outfall No. 005 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Light Brown
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
1 I� 3 4 5
R
S. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
l is no solids and 5 is the surface covered with floating solids:
2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where L is no solids and 5 is extremely muddy:
1 2 4 5
7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there any evidence of errosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit lain://portal.ncdenr.org/web/wg/ws/suJupdessw#tab-4
Permit No.: NCG030000 or Certificate of CoveraN/C/G
Facility Name: Winston Steel
County: Forsyth Phone No. , $ '
Inspector: Neal McDuffie (RAL)
Date of Inspection, 12/09/13
Time of Inspection
1017
Total Event Precipitation (inches): 0.32
Was this a "Representative Storm Event" as defined by the permit?
(See information below.)
/yes ❑ No
Please verify whether Qualitative Monitoring must be performed during a "representative storm event or "measureable storm
event" (requirements vary, depending on the permit.)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." however, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
A "measurable storm event' is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local DWQ Regional Office.
this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
SWU-242-020705

1. Outfall Description
Outfall No. 406 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Light Orange
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weals chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
1 I�`.,J 3 4 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
1 is no solids and 5 is the surface covered with floating solids:
0 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
1 2 4 5
7. is there any foam in the stormwater discharge? Yes No
8. is there an oil sheen in the stormwater discharge? Yes No
9. is there any evidence of errosion or deposition at the outfaIl? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

�G
7.
7 ,rt
Y
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit http:llportal.ncdenr.org/web/wg/ws/su/npdessw#tab4
Permit No.: NCG030000 or Certificate of Covera€N/C/G
Facility Name: Winston Steel
County: Forsyth Phone No. '(115-1
Inspector: Neal McDuffie (RAL)
Date of Inspection: 12/09/13
Time of Inspection:
0940
Total Event Precipitation (inches): 0.32
Was this a "Representative Storm Event" as defined by the permit?
(Se information below.)
Y s ❑ No
Please verify whether Qualitative Monitoring must be performed during a "representative storm event or "measureable storm
event" (requirements vary, depending on the permit)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm cVcnt measuring greater than. 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local DWQ Regional Office.
this signature, I cer fx that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
S WU-242-020705

1. Outfall Description
Outfall No. 007 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Medium Brown
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, wbere I is clear and 5 is very cloudy:
1 2 3 1 4 1 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
1 is no solids and 5 is the surface covered with floating solids:
2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where 1 is no solids and 5 is extremely muddy:
1 2 4 5
7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there any evidence of errosion or deposition at the outfail? Yes No
10. Other Obvious indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant further investigation.

0 11;;ii�Y.
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit hiip://portat.ncdenr.org/web/wq/ws/su/npdessw#tab-4
Permit No.: NCG030000 or Certificate of Covera€N/C/G
Facility Name: Winston Steel
County: Forsyth Phone No. /,VA
Inspector: Neal McDuffie (RAL)
Date of Inspection: 12/09/13
Time of Inspection:
0923
Total Event Precipitation (inches):
0.32
Was this a "Representative Storm Event" as defined by the permit?
(Sinformation below.)
/Y--e s a No
Please verify whether Qualitative Monitoring must be performed during a "representative storm event or "measureahle storm
event" (requirements vary, depending on the permit.)
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be performed during a
"representative storm event" or during a "measurable storm event." However, some permits do not have this requirement.
Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours (3 days) in which no storm event measuring greater than, 0.1 inches has occurred. A single storm event may contain up to
10 consecutive hours of no precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must h
able to document that a shorter
approval from the local D WQ Regional Office.
this siggature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
SWU-242-020705

1. Outfall Description
Outfall No. 008 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Light Brown
3. Odor: Describe any distinct colors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,etc.)
None
4: Clarity: Chose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy:
3 4 5
5. Floating Solids: Choose the number which best describes the amount of foating solids in the stormwater discharge, where
I is no solids and 5 is the surface covered with floating solids:
ICJ 2 3 4 5
6.'Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater
discharge, where I is no solids and 5 is extremely muddy:
1 2 r 3 4 5
7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there any evidence of errosion or deposition at the outfall? Yes No
I& Other Obvious indicators of Stormwater Pollution:
List and
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or errosion/deposition may be indicative of pollutant exposure.
These conditions warrant finther investigation.

Winston Steel - Winston-Salem, NC
FLOWCHART- OUTFALL 001 & 002
TOTAL DISCHARGES CALCULATED BASED ON 6.20 ACRE DRAINAGE AREA USING A COMPOSITE RUNOFF COEFFICIENT
OF 0.75 BASED ON 5.70 ACRE GRAVEL, 0.SO ACRE IMPERVIOUS
......_ ............... _.-...:...:... .... ::::-.:.....
- -
0.10
0.0125
0.15
0.0188
0.20
0.0250
0.25
0.0312
0.30
0.0375
0.35
0.0438
0.40
0.0500
0.45
0.0562
0.50
0.0625
0.55
0.0688
0.60
0.0750
0.65
0.0812
0.70
0.0875
0.75
0.0938
0.80
0.1000
0.85
0.1060
0.90
0.1120
0.95
0.1190
1.0
0.125
1.1
0.I38
1.2
0.150
1.3
0.162
1.4
0.175
1.5
0.188
1.6
0.200
1.7
0.212
1.8
0.225
1.9
0.238
2.0
0.250

RESEAR& & ANW� C4
LAbomvm'�'ESP hC.
Analytical 1 Process CUnsultaGions
t 'r Phone [phone]
CHAIN OF CUSTODY UlFCORD
I WATER I WASTEWATER 11 Wi1SC. 1
COMPF,i'I•r ��} �[[ r pp 11
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SAMPLER NAME (PL ASE PRINT)
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RE15(ARCh & ANALyTlCA[
� ­i_ LAbORATORIES� INC.
Anclyllcol/P+ocess Consultations
June 24, 2013
Winston Steel LLC
1947 Union Cross Road
Winston-Salem, NC 27107
Attention: Mr. Mike Carcieri
Chemical Analysis for Stormwater Sampling identified as Outfalls 001-007 at Winston Steel LLC- Winston-Salem, N(
o•
sy NC #34 Z
1.
Project Number: N/A
NPDl?S HNCG11301100
Parnmelcr
Quantilation
Limit
LIEIL
001
imIL
002
m /L
003
m 1L
004
WED
009
ne !L
006
m !L
007
m !L
009
m L
Cut-off
Concentration
m L
Total Suspended Solids
5.0
<1-0
18.0
<1.0
53.0
12.0
13.0
11.0
68.0
100
Oil & Greasr
5,0
<5.0
<5.0
<5"0
<5.0
<5.0
<5.0
<5.0
<5.0
30
Lead
0.005
<0.005
<0.005
1 <0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0-033
pit
0.1 Sid. Units
1 6.61
6.52
6.54
1 6.73
6.62
1 6.89
6.78
1 6.51
1 6.0 - 9.0
Sample Number
759699
759700
759701
1 759702
759703
1 759704
759705
1 759706
Sample hale
06/06/13
06l00113
1 06/06/13
1 06/06/13
1 06/06/13
1 06/06/13
06/06/13
00/06/13
Sample Time
1322
1608
1 1330
1 1614
1621
1 1630
1634
1640
Rainfall 2.19 in.
Event Duration 17 min.
Results of Visual Monitoring of Slormwater
at Winston Steel - Winston-Salem, NC
Outfall Identified as Outfall 001 & 002
11,
1'rn'ect Number: N/A
NPDES r'lNCG030000
Slormwaler
Discharge
Charterislics
Frequency
Monitoring
Location
001
Monitoring
Location
002
Monitoring
Location
003
Monitoring
Location
004
Monitoring
Location
Oils
Monitoring
Loealinu
006
Monitoring
Location
007
Monitoring
Location
008
Monitoring
Type
Color
Scmi-Annual
Clear
Clear
Light Brown
Light Grey
Light Brown
Light Brown
Light Grey
11rowo
Visual
Semi-Annuat
None
None
None
None
None
None
None
.-Light
None
Visual
Semi -Annual
Clear
SL.Turbid
S1, "l urbid
SL.Turbid
S1,. Turbid
SL. Turbid
SI_ Turhid
Sl.. Turbid
Visual
NOdar
n Solids
Scmi-Annual
None
None
None
None
Light
None
None
None
Visual
nded Solids
Semi -Annual
None
Li ht
Light
Light
Moderate
Light
Moderate
Light
Visual
Scmi-Annual
None
None
None
None
None
None
None
None
Visual
Oil Sheen
Scmi-Annual
None
None
None
None
None
Norie
None
None
Visual
Other obvious
on idicators of
slormwater Pollution
None
None
None
None
None
None
None
None
mgll. = miIligratns per Liter= parts her million (ppm) BQL. Below Quantilation Limits <= leas than or Below Quantilation Limit (13QL)

1f ES1EARCh & ANA[yTiCA[
LAbORATORIESt INC.�weJI
N N C #3 zj
Analytical/Process Consultations
4
';� �, ',o,R�P;
.tune 24, 2013
Winston Steel LLC
1947 Union Cross Road
Winston-Salem, NC 27107
Attention: Mr. Mike Carcieri
Chemical Analysis for Stormwater Sampling identified as Winston Steel (Outfalls 001-008), collected 06 June 2013
1•
Project Number: NIA
NPDCS9: NCG030000
Sample
RAL
Sampling
Sampling
Total
Oil
Total
PH
Temperature
Date
Identification
Sample
Date
Time
Suspended
&
Lead
Analyzed
Number
Solids
Grease.
(mg1L)
(mg/L)
(mg/L)
(SU)
(°C)
06106, 06/08 &
001
759699
06/06/13
1322
<1.0
<5.0
<0.005
6.61
22.9
06/13/13
06106, 06108 &
002
759700
06/06/13
1608
18.0
6.0
<0,005
6.52
21.7
06/13/13
06106, 06108 &
003
759701
06/06/13
1330
<1.0
<5.0
<0.005
6.54
23.0
06/13/13
06106, 06/08 &
004
759702
06/06/13
1614
53.0
<5.0
<0.005
6.73
23.2
06/13/13
06106, 06108 &
005
759703
06/06/13
1621
12.0
<5.0
<0.005
6.62
22,7
06/13/13
06/06, 66/08 &
006
759704
06/06/13
1630
13.0
<5.0
<0.005
6.89
23.4
06/13/13
06/06, 06108 &
007
759705
06/06/13
1634
11.0
<5.0
<0.005
6.78
22.1
06/13/13
06/06, 06/08 &
008
759706
06/06/13
1640
68.0
<5,0
<0.005
6.51
22.6
06/13/13
Analyst: Gil, Yj, NIS & JC
mg/L = milligrams pet' Liter = parts per million (PlIM)
<- Icss than or Below Quantilalion Limit (13QL)
5U — Standard Units
°C = Degrees Celcius

STORM WATER DISCHAPIII Oo )TFALL (SDO)
MONITORING t..PORT
GENERAL PERMrr NO. NCG030000
CERTIFICATE OF COVERAGE NO. NCG
FACILITY NAME Winston Steel LLC
PERSON COLLECTING SAMPLE(S) Glenn Price (RAL)
CERTIFIED LABORATORY(S) R & A Laboratories, Inc. Lab # 34
Lab #
SAMPLES COUE r1i17 DURING CALI3NDAR YEAR: 2013
(all samples collected during a calendar year, shall be reported no later
than January 31 of the following year)
r) COUNTY Fors th
PHONE NO.
(SIGNATURE OF PERMITI-131- Olt DE:SIGNI,L)
13y this signature, 1 certify that this report is accurate and
complete to the best of my knowledge.
Part A: Specific Monitoring Requirements for stormwster discharges from secondary containment structures associated with Petroleum Bulk Stations and Terminals and stornnvaler
discharges from Oil Water Separators
Outfall
No.
Date
Sample
Collected
50050
00556
00545
01051
46000
00400
Total
Flow
Oil and
Grease
Total
Suspended
Solids
Lead, Total
Phenols
pH
rno/dd/yr
MG
mg/l
mg/1
mg/l
mg/I
unit
001
06/06/13
0.272
<5.0
<1.0
<0.005
6.61
002
06/06/13
0.272
<5.0
18-0
<0.005
`
6.52
003
06/06/13
0.272
<5.0
<1.0
<0.005
6.54
004
06/06/13
0.272
<5.0
53-0
<0.005
6.73
005
06/06/13
0.272
<5.0
12.0
<0.005
6.62
006
06/06113
0.272
<5.0
13.0
<0.005
6.89
007
06/06/13
0.272
<5.0
11.0
<0.005
6.78
008
06106113
0.272
<5.0
68.0
<0.005
6.51
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? Tycs X no
(if yes, complete Part 13)
Part B- Vehicle Maintenance Activity Monitoring Requirements
Pan A dxa nai apply. This 5.11hy don nal d1sch.,p
starmwamr Iro .--dary eonalnmem urucm— of
ou"ier separalam
Outfall
No.
Date
Sample
Collected
50050
00556
01051
38260
00545
00400
Total
Flaw
Oil and
Grease
Lead, Total
Recoverablel
Detergents
(MBAS)Z
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/drY r
MG
m 1
uell
m l
mall
unit
al/nu,
STORM EVENT CHARACT1;RISTICS:
Dale 6/6/2013
Total Event Precipitation (inches): 2,18
Event Duration (hours): 17
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches): NIA
Event Duration (hours): N/A
Mail Original and one copy to:
Attn: Central Files
DCHNR
Division of Environmental Mgt.
P.O. Box 29535
Raleigh, NC 27626-0535
Form M R-18
Page I of 2

�0F W A Tt. p%
F-f
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCG030000 or Certificate of Coverage No.:
Facility Name: Winston Steel
County: Forsyth Phone No. -702 Iz f 5 1
Inspector: Glenn Price (RAL) f -
Date of inspection: 616I2013
By this signature, 1 certify that this report is accurate and complete to the best of my knowledge:
a"- Nl-L R) WjAf Za�
(Signature of Permitee or Designee)
1. Outfall Description
OutfaIl No. 001 Structure (pipe, ditch, etc.) Storm Grate
Receiving Stream.:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Clear
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very cloudy:
1 2 3 4 5 6 7 8
.. Page 1
S WU-242-020705
9 10

5. Floating Solids
Choose the number which best describes the amount of floating solids in the. stormwater discharge where l is no
solids and 10 is the surface covered with floating solids:
11 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where I is no
solids and 10 is extremely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes No
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediatley below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indiciative of conditions that warrant further investigation and corrective action.
Page 2
SWU-242-020705

�r-
p* vJA rERQ�
r-
a �
T'
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCG030000 or Certificate of Coverage No.:
Facility Name: Winston Steel
County: Forsyth Phone No. '3
Inspector: Glenn Price (RAL)
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
0-�A"V,t MQLLCjjW
(Signature of Perm-itee or Designee)
1. Outfall Description
Outfall NO. 002 � - n ^ �Structur�e, ditch, etc.) Storm Grate
ReceivingStream:
Describe the industrial activities that occur within the outfali drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Clear
3. Odor
Describe any distinct odors that the discharge may have (i•e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very cloudy:
l 1 3 4 5 6 7 8 9 10
SWU-242.020705
Page 1

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where 1 is no
solids and 10 is the surface covered with floating solids:
�12 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy-
1 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes Na
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes Na
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediatley below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indiciative of conditions that warrant further investigation and corrective action.
Page 2
swU-242-020705

C
Permit No.: NCG030000
_4�aF v4 ti r�Ra�
7:
a �
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
or Certificate of Coverage No.:
Facility Name: Winston Steel
County: Forsyth Phone No.
Inspector: Glenn Price (RAL)
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Perrnitee or Designee)
1. Outfall Description
Outfall No. 003 Structure (pipe, ditch., etc.) Storm Grate
Receiving Stream:QAY)
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Brown
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where I is clear and 10 is very cloudy:
l 2 C� 4 5 6 7 8 9 10
SWU-242-020705
Page 1

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where L is no
solids and 10 is the surface covered with floating solids:
-11 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy:
2 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Screen
Is there any oil sheen in the stormwater discharge? Yes Nv
9. Deposition at Outfall
Is there deposition of material (sediment,'etc.) at or immediatley below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or inimediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indiciative of conditions that warrant further investigation and corrective action.
Page 2
SWU-242-020705

`oQF w A r�ROG
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCG030000 or Certificate of Coverage No.:
Facility Name: Winston Steel
County: Forsyth Phone No. 2�Lu COC f
Inspector: Glenn Price (RAL) 1
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
1. Outfall Description
Outfall No. 004 Structure (pipe, ditch, etc.) Storm Drain
Receiving Stream: _ Sck C 1u n
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Grey
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very cloudy:
1 2 1 3 1 4 5 6 7 8 9 10
Page 1
S WU-242-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where 1 is no
solids and 10 is the surface covered with floating solids:
1..�1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where I is no
solids and 10 is extremely muddy: .
1 2 L�J 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes No
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediatley below the outfall? Yes Nn
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes 1Vo
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Mote: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion maybe
indiciative of conditions that warrant further investigation and corrective action.
Page 2
S%V242-020705

`o�o� wRr$q��
C, �
?_
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCGO30000 or Certificate of Coverage No.:
Facility Name: Winston Steel
County: Forsyth . Phone No. 3(a 7EL2
Inspector: Glenn Price (RAL)
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
1. Outfall Description
Outfall go. 005 �� Stru turec,� (pipe, ditch, etc.) Storm Drain
Receiving Stream: (\lJ L�y1 1�—
Describe the industrial activities -that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Brown
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where l is clear and 10 is very cloudy:
1 2 3 I4 5 6 7 8 9 10
Page 1
S WU-242-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where 1 is no
solids and 10 is the surface covered with floating solids:
1 �.J 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy:
1 2 3 5 6 7
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes No
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediatley below the outfall?
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
8 9 10
Yes No
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion maybe
indiciative of conditions that warrant further investigation and corrective action.
Page 2
SWU-242-020705

0�4F W A r�Rpq
o -c
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCG030000 or Certificate of Coverage No.:
Facility Name. Winston Steel ��7
County: Forsyth Phone No. �v3�j -7 l Q I
Inspector: Glenn Price (RAL)
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
n1 , i _ 4
(Signature of Permitee or Designee)
1. Outfall Description
Outfall No_ 006 Structure (pipe, ditch, etc.) Storm Drain
Receiving Stream: Wn
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Brown
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very cloudy:
1 2 L._. 3 4 - 5 6 7 8 9 10
L
SWU-242-020705
Page 1

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where I is no
solids and 10 is the surface covered with floating solids:
2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy:
2 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes No
9, Deposition at Outfall
Is there deposition of material (sediment, etc-) at or irnmediatley below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion maybe
indiciative of conditions that warrant further investigation and corrective action.
Page 2
swu-242-020705

7
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCG030000 or Certificate of Coverage No.:
Facility Name; Winston Steel
County: Forsyth Phone No. Lb 7ffie d El
Inspector: Glenn Price (RAL)
Date of Inspection: 6/6/2013
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitce or Designee)
1. Outfall Description
Outfall Na. 007 �� c(pipe, ditch, etc.) Storm Drain
ReceivingStream: I�
Describe the industrial activities that occur within the outfall drainage area:
C
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Grey
3. Odor
Describe any distinct odors that the discharge may have (Le., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very cloudy:
1
5 WU-242-020705
Page 1
10

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where 1 is no
solids and 10 is the surface covered with floating solids:
i 1 l 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy:
1 2 3 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sbeen
Is there any oil sheen in the stormwater discharge? Yes No
9, Deposition at Outfall
is there deposition of material (sediment, etc.) at or immediatley below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Otber Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indiciative of conditions that warrant further investigation and corrective action.
Page 2
S WU-242-020705

`4�oF \N A,eRpG
>_ ti
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NCO030000 or Certificate of Coverage No.;
Facility Name: Winston Steel
County: Forsyth Phone No. 7
Inspector: Glenn Price (RAL)
Date of Inspection:
6/6/2013
By this signature, i certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permitee or Designee)
1. Outfall Description
Outfall No. 008 Structure (pipe, ditch, etc.) Storm Drain
Receiving Stream: c�pQ'-�n 0L��
Describe the industrial activities that occur within the outfall drainage area:
2, Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors:
Light Brown
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.)
None
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and- 10 is very cloudy:
i
S WU-242-020705
1 3
4 5 6 7 8 9 10
Page 1

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where 1 is no
solids and 10 is the surface covered with floating solids:
I 1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge where 1 is no
solids and 10 is extremely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there any oil sheen in the stormwater discharge? Yes Na
9. Deposition at Outfali
Is there deposition of material (sediment, etc.) at or immediatley below the outfail? Yes Na
10. Erosion at Outfall
Is there erosion at or immediatley below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe None
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion maybe
indiciative of conditions that warrant further investigation and corrective action.
Page 2
SWU-242•020705

Winston Steel - Winston-Salem, NC
FLOWCHART - OUTFALL 001 & 002
TOTAL DISCHARGES CALCULATED BASED ON 6.20 ACRE DRAINAGE AREA USING A COMPOSITE RUNOFF COEFFICIENT
OF 0.75 BASED ON 5.70 ACRE GRAVEL, 0.50 ACRE IMPERVIOUS.
RAINFALL
_ ........ - .
........:........
................
. ,.. ......:...:�:.- .::•w.:.- {INCHES) -- ------- - ---... .........
TOTAL DISCHARGE
-..:....r. .::.:.... :.......: _. CMG) -
0.10
0,0125
0.15
0.0188
0.20
0.0250
0.25
0.0312
0.30
0.0375
0.35
0.0438
0.40
0.0500
0.45
0.0562
0.50
0.0625
0.55
0.0688
0.60
0.0750
0.65
0.0812
0,70
0.0875
0.75
0.0938
0.80
CA000
0.85
0.1060
0.90
0.1120
0.95
0.1190
1.0
0.125
1.1
0.138
1.2
0.150
1.3
0.162
1.4
0.175
1.5
0.188
1.6
0.200
1.7
0.212
1.8
0.225
1.9
0.238
2.0
0.250

RESEARCh & ANAlyliCA1
LAboRATORIES, INC.
Analytical f Process Consultations
Phone [phone]
CHAIN OF CUSTODY RECORD
WATER I WASTEWATER I MISC,
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SAMPLER NAME PLEASE PRIN
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CONTACT PHONE
SAMPLER SIGNATURE
SAMPLE NUMBER
(LAB USE ONLY)
DATE
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
December 4, 2012
Christine Maclaren
Winston Steel LLC
1947 Union Cross Rd
Winston Salem, NC 27107
Dee_ Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Winston Steel LLC
COC Number NCG030528
Forsyth County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG030000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG030000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as Dutlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal,ncdenr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raiegh, Noah Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone]' FAX: [phone]
Internet: www.ncwat--M,uality.org
An Fq jai Opportunity 1 i s -lrrraiive A,;9on Employer
One
Nc ►rthCarolina
vMaturalllf

Christine Maclaren
December 4, 2012
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections 8, C. A lower TSS benchmark of SO mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C. The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections 8, C, D. Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
I
b/�LLdL/�,J',�WL G1
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Winston-Salem Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030528
STO RM WATE R
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Winston Steel LLC
is hereby authorized to discharge stormwater from a facility located at:
Winston Steel LLC
216 Junia Ave
Winston Salem
Forsyth County
to receiving waters designated as Salem Creek (Middle Fork Muddy Creek), a class C
waterbody in the Yadkin River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, 11, III, and IV of General Permit No.
NCG030000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41" day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

WINSTON STEEL LLC
. . 1947 Union Cross Road ,
f
Winston-Salem, NC 27147 .
PHONE: [phone]: [phone] *`QUEo��'}
March 22, 2012
Mr. W. Corey Basinger
Water Quality Supervisor
North Carolina Division of Water Quality
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, North Carolina 27107
Subject: Response to Compliance Evaluation Inspection & Notice of Violation
NOV-2011-PC-0077
Dear Mr. Basinger:
Enclosed is one (1) copy of Winston -Steel LLC response to the above referenced Notice of Violation
prepared by our environmental consultants, Research & Analytical Laboratories, Inc. (PAL). If you
should have any questions concerning the information provided in our response please feel free to
contact Mr. James Cheshire at 336-996-2841, or myself at any time.
Sincerely,
Christine MacLaren
Human Resources Manager
Winston Steel LLC
Lyndon Steel Company LP
336.788.6151 ext. 218
Enclosure

I?ESEARCh & ANAIyTiCA!
LZORATORfES, INC.
Analyticsl/Process ConsJcations
16 March 2012
Mr, W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salcin Regional Office
North Carolina Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street
Winston-Salem, North Carolina 27107
Subject: Response and Proposed Corrective Action Concerning Compliance
Evaluation Inspection and Notice of- Violation — NOV — 2011 — PC -- 0077
NPDES General Stormwater Permit NCG030000 Certificate of Coverage
NCG030528 Winston Steel LLC,_ 216 Junia Avenue,_ Winston-Salem,
North Carolina Forsyth County
Dear ,ylr. Basinger:
In response to DENR's Notice ol'Violation concerning the above referenced
industrial facility currently idcntified as Winston -Steel, LLC. Research & Analytical
Laboratories, Inc. (RAL) has prepared the following response upon conclusion of their
site visit on 07 March 2012. It is important to note that i2AL (Dennis R. Herzing, P.E.
and James M. Cheshire) prepared the required Stornwater Management Plan / SPCC
Plan for Winston -Steel in October of 2006. Enclosed is one (1) copy of Both plans with
an updated Site Plan drawn to scale including location coordinates and elevation
measurements referenced to sea level. The Plans and Site Map were used to document
the Storm -,eater Management Plan requirements for this facility relative to the NI'DES
General Storinwater Permit (NCG03000) which expired on 31 August 2007.
The following responses / corrective actions have been prepared to address the
deficiencies identified in this most recent Notice of Violation by DENR in the same
chronological order as it appeared in the 28 February 2012 NOV Report.
1) The general location map (GLM) does not show surface waters or the
receiving stream...
Enclosed as pzi'rt o1-thc SP; / SPCC is an updated / revised Site Plan oe GLM
shown in Appendix 2. The GLM flocs not shoe- surface_ waters or the
receivinL- stream because stormwater runolY discharges into a municipal
separate storm sewer maintained by the City of Wiq� ton-Salein. The GLM
does, however, show the stc�r��water discharge c�utfalls (SDO) and accurate
P 0. Box 473 • 106 Short Street • KernerWville. North Carolina 27284 • 336-996-2841 • Fax [phone]
vnvw.randalabs.conl

latitudes and longitudes for each SDO. It was suspected, based upon the
"schematic" trap ofthe site shown to RAL during the Site Inspection.that
DENR may not have been looking at a Site Map or GLM prepared by RAL.
This "schematic" appears to have inadvertently rnislocated the SDO's in
relationship to an adjacent street, Junia Ave (see Enclosed.Schematic Map).
2) The Site Map (SM) does not delineate drainage areas clearly and does not
show all industrial activity areas...
The revised site map shown in Appendix-2 of the SP3 / SPCC Plan delineates
drainage areas clearly for SDO's 001 and 002.shokving= i runoffcoefficient of
0.75. It is estimated that approximately 90% of the property Consisting of
buildiiig rocif/ liardpah uhpavOd parkin.o lot is moderately impervious to
stormwater runoff. Also included on the.GLM is shown. all industrial activity
areas such as finished product storage area and loading /unloading areas.
3) There is a general statement that no spills have occurred at the facility in the
past three (3) years...
It has been recommended that a semi-annual review audit be conducted based
on the S P 3 — General Permit Action item Summary shown on page ii and
Section 4.6 page 3.
4) The SDO's «sere certified in November, 2008...
Recommendation the same as item H3.
3) There is no feasibility study in SP3 as required by Part H. Section A,
Paragraph2 of the general permit...
It,is anticipated that the required feasibility study will be completed in 2012.
6) The Spill Prevention and Response Plan (SPRP) as required in Part 11, Section
A. Paragraph 3 of the general permit, should include a listing of emergency
contacts with telephone numbers...
These contacts are listed in Appendix 5 of the SPCC-Plan on pages 4 and 5.
Contacts not included in Plan; but identifled,in this OENR inspeetion will be
included in the Annual Review Update.
7) The SP3 does not address Preventative Maintenance and Good Housekeeping
as required in Part 11, Section A, Paragraph 4...
This-infoi oration is addressed -in the SP3 on page'3 section-4.0 Best
Management Practices (BMP).

8) The SP3 does not address training as required by Part I1, Section A. Paragraph
5 of the general permit...
This information is addressed in the SP3 on page S,;Scction 4.9 Employee
Training. The Employee Trainer designated for this facility was reported to
be Christine MacLaren, P1-IR.
9) The SP3 does not address annual reviews of the SP3 as required in Part 11,
Section A, Paragraph 7...
This information is addressed in the SP3) on page 8, Scction 41 8-Annual Plan.
Review.
10) Site inspections as required by Part 11, Section A, Paragraph 8, have not been
accomplished...
This information is addressed in the SP3 on page 5, Section 4.6 Stonttwater
Discharge Point -Inspection Program. Section 4.5 Erosion l Sediinentation
Control facility Inspection and Maintenance_P_rogran3, and'Scction,2.0 (page
2) Pennit Rc birements / Corn liiini c.Activities. 'Documentation of this
activity through serni-annual,audit.and review is recommended ror this facility
and 'includes both SP3 and SPCC Plans.
1 1) The SP3 currently identities two (2) SDO's, one in the southeast corner of the
site and the other in the southwest corner of the site...
We aLree that the "scltematic reap" you are referring to appears to be
incorrect; however, RAL did not,proNide this ntirp. t"Appendix 2 of the SP3
shows an updated. Site Plan which includes SDO's 001 and 002, with location
coordinates and ,round el6vati6ns. The objective in selecting- these SDO's
was (lctennined by the lowest elevationipoint with the greatest stonnwater
irnpact'to the property.
12) Analytical and qualitative monitoring (AM & QM) records were reviewed...
Enclosed -is all of the Ay1 / QM serni-annual data -required by section B & C
of the general permit from 2007 throdo, 12011 with the exception of TTO's.
There were no benchmark exceedances reported during this. period.
13) According to Mr. Collins, once metal structures are built they are often wiped
down with a thinner...
The testing of Total Toxic Or anics (TTO) will colrrmenc-e during the next
stonnwater sampling event.

Site RCN'le%y
1) The containment pallet used to store 55-gallon drums of paint...
The containment Mallet will he replaced or repaired Mthin the next 30 days.
It is important to note that Winston -Steel has already begun the implementation of
correcting the deficiencies noted in DENR's Notice of Violation Report. Full compliance
with General Permit is expected to be achieved within the next thirty (30) days.
Thank you for your thorough review and if you should have any further response,
please so advise.
Sincerely,
.fames M. Cheshire
President/CEO
Research R Analytical Laboratories, [tic.

Mr. Cheshire,
I reviewed your response to the NOV we sent for the inspection at Winston Steel. Here are my
comments to your responses listed in the same order that you address them in your letter, which is the
same way they are listed in the original NOV:
1.
2.
3.
a. The general location map (GLM) and the site map (SM) are two different requirements
of the stormwater pollution prevention plan (SP3) and each has its own specific
requirements. Although your map is a good map, it does not meet all the requirements
of either the GLM or the SM. You MUST have two different maps. Please refer to the
new general permit for the exact requirements of each.
b. You stated that the GLM does not show the surface waters or the receiving stream
because the discharge is to the Winston Salem MS4, however, showing adjacent surface
waters, especially the ultimate receiving stream, is a requirement of the GLM regardless
of whether initial discharge goes to the M54. Besides, Winston Steel should know at
what point in the MS4 their discharge eventually enters the actual receiving stream.
C. The GLM still does not show whether the receiving waters are impaired.
d. Neither the GLM nor the SM show ALL SDOs with accurate lats/longs. There are at least
three other drop inlets on the property, in addition to the two you have identified as
SDOs, as well as two curb inlets on the north side of the building along Junia Avenue
that probably also receive drainage from the site. ALL SDOs need to be identified and
monitored and if the facility wishes to apply for representative outfall status (ROS) at
some point in the future, we'll probably be able to agree to a reduction of analytically
monitored SDOs. Please refer to the attached map of the city of Winston-Salem's MS4 in
that area.
a. With the additional five SDOs, the drainage areas are NOT clearly delineated on the SM.
b. You indicate that approximately 90 percent of the site is impervious. This should be
broken down into the separate drainage areas that correspond to each SDO.
C. I was told during the inspection that the west end of the building is the raw product
storage area and the east end is the finished product storage area. You state that the
finished product areas and loading/unloading areas are identified on the map. However,
unless I'm just missing it, the only things identified on the map are the raw product
storage (which according to what I was told in the inspection is inaccurate), kerosene
and diesel tanks, and the containment pallet. Loading/unloading areas, disposal areas,
etc, are not identified, although, if all that was shown on the small SM that you have, it
may become quite busy and difficult to read. I suggest a larger site map.
You state that it has been recommended that a semi-annual review audit be conducted
based on the SP3 — General Permit Action Item Summary shown on page ii and Section
4.6 page 5. I've reviewed both sections of the SP3 that you mention above and neither
mention anything about the requirement to update the spill list annually, which is what
was initially written up.
Again, you state that it has been recommended that a semi-annual review audit be
conducted based on the SP3 — General Permit Action Item Summary shown on page ii
and Section 4.6 page 5. I've reviewed both sections of the SP3 that you mention above

and neither mention anything about the requirement to recertify the SDOs annually,
which is what was initially written up.
5.
a. OK
6.
a. I reviewed the appendices of the SPCC plan and did not find any such listing of
emergency contacts. The entities I suggested for you to list in the Spill Prevention and
Response Plan (SPRP) of the SP3 are not listed anywhere that I can see. Although this is
NOT a specific requirement, it is highly recommended.
7. a. The specific Preventative Maintenance/Good Housekeeping Program is not directly
addressed in section 4.0 (page 3) of the SP3 as you indicate, at least not to the extent I
think it should be.
8.
9.
10.
11.
a. OK — but no training has been accomplished.
a. OK — but annual reviews are not being accomplished.
a. None of the three sections of the SP3 that you mention, sufficiently address the Facility
Inspection Program as I believe the permit requires it to. This is intended to be an
OVERALL site inspection. No comprehensive site inspections have been done or
recorded. This item kind of goes hand in hand with item 7, above.
a. Your response indicates that you've granted Winston Steel representative outfall status
(ROS) yourself, given the fact that there are at least S other potential SDOS, and you
state, "the objective in selecting these SDOs was determined by the lowest elevation
point with the greatest stormwater impact to the property." ALL SDOs must be
identified and monitored unless DWQ grants ROS if so warranted and officially
requested by Winston Steel.
12.
a. I did not review AM/QM records, but these records need to be kept on site at all times
and AM/QM need to be accomplished according to the new permit requirements, not
the old permit — refer to #14 below.
13.
a. Suggest they develop a Solvent Management Plan rather than test for TTOs; it's a much
less expensive option.
14. As a general statement, you admit that the SP3 was written based on the previous
edition of the permit. The current SP3 even talks about the "annual stormwater
samples", while the new permit requires semi-annual sampling. It is highly suggested
that the new permit be reviewed in detail and the SP3 rewritten to address all the
requirements of the new permit.
Please feel free to contact me as questions arise.

Boone, Ron
From:
Boone, Ron
Sent:
Friday, April 27, 2012 10,34 AM
To:
'Christine MacLaren'
Subject:
RE: Winston Steel
Ms. McClaren,
Granted. Let me know if I may be of any assistance.
Thank you!
Ron Boone
NC DEN Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: [e-mail]
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Christine MacLaren[mailto:[e-mail]]
Sent: Thursday, April 26, 2012 11:04 AM
To: Boone, Ron
Subject: RE: Winston Steel
Mr. Boone - I have been working on the NOV compliance for Winston Steel. After a thorough review of the plan
that R&A revised for us, I find that it is not very well organized, cumbersome, and, as you have noted, does not
meet requirements for the current permit. I respectfully request a revised deadline of May 9 to make revisions
for the plan and update it according to the current permit.
Thank you,
Christine
Christine MacLaren, PHR
Human Resources Manager
Winston Steel LLC
Lyndon Steel Company LP
1947 Union Cross Road
Winston-Salem, NC 27107
336-785-0848 ext. 218
336-788-8835 fax
336-972-0436 cell
[e-mail]

From: Boone, Ron [mailto:[e-mail]]
Sent: Friday, March 30, 2012 11:59 AM
To: James Cheshire
Cc: Basinger, Corey; Christine MacLaren
Subject: Winston Steel
Jim,
Attached are my comments to your response to the NOV we sent Winston Steel for their stormwater inspection. I've
also attached a copy of the current general permit, copies of the City of Winston-Salem's M54 in their immediate area
(provided by the city's stormwater division), and some topos of the area. Please keep in mind that their ultimate
receiving stream is Salem Creek. Please DO NOT hesitate to call me if you have questions on addressing the remaining
issues. I'm more than happy to assist.
Regards,
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: ron.boone ncdenr. ov
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

Boone, Ron
From:
Boone, Ron
Sent:
Tuesday, May 08, 2012 8:25 AM
To:
'Christine MacLaren'
Subject:
RE: Winston Steel
Ms. McClaren,
I will accept this (along with previous correspondence) as your official response to the NOV we sent. I will print out
everything and place it in your file. I trust that you will follow through on everything, so there's no need for me to come
back out and do a re -inspection. If things aren't in order during the next inspection, we'd probably have to go ahead and
elevate to the next level of compliance/enforcement.
I want to stress to you, however, the most important thing is that All (including all drop inlets on site and curb inlets
along the street that your stormwater flows into) SDOs on site be monitored in accordance with the permit until such
time that you request ROS from us and we grant it. I can tell you that ROS is generally not granted without sufficient
monitoring results that show that the flow at each SDO is generally the same in nature. I cannot remember what data
you had, but I do remember you were NOT monitoring all SDOs and therefore had no data for those that you weren't
monitoring. Therefore, if your ultimate aim is to request ROS, then you may want to monitor those outfalls more often
in order to compile a representative data set that we can use to help justify granting you ROS. If you have any questions,
don't hesitate to call me.
Regards,
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: [e-mail]
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Christine MacLaren[mailto:[e-mail]]
Sent: Monday, May 07, 2012 4:38 PM
To: Boone, Ron
Subject: RE: Winston Steel
Ron
I am attaching several documents for your review. Please start with the first pdf file named "Winston Steel
Response" and then "WSS supplement to r&a".
I sincerely believe that we have made great progress in ensuring our Stormwater Mgmt Plan is correctly
administered.
Thanks

Christine
Christine MacLaren, PHR
Human Resources Manager
Lyndon Steel Company LP
Winston Steel LLC
1947 Union Cross Road
Winston-Salem, NC 27107
336-785-0848 ext. 218
336-788-8835 fox
336-972-0436 cell
cmaclaren(Rhdonsteel.com
From: Boone, Ron [mailto:[e-mail]]
Sent: Friday, April 27, 2012 10:34 AM
To: Christine MacLaren
Subject: RE: Winston Steel
Ms. McClaren,
Granted. Let me know if I may be of any assistance.
Thank youl
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: [e-mail]
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Christine MacLaren[mailto:cmaclaren(4)iyndonsteel.com]
Sent: Thursday, April 26, 2012 11:04 AM
To: Boone, Ron
Subject: RE: Winston Steel
Mr. Boone - I have been working on the NOV compliance for Winston Steel. After a thorough review of the plan
that R&A revised for us, I find that it is not very well organized, cumbersome, and, as you have noted, does not
meet requirements for the current permit. I respectfully request a revised deadline of May 9 to make revisions
for the plan and update it according to the current permit.
Thank you,
Christine
Christine MacLaren, PHR

Human Resources Manager
Winston Steel LLC
Lyndon Steel Company LP
1947 Union Cross Road
Winston-Salem, NC 27107
336-785-0848 ext. 218
336-788-8835fox
336-972-0436 cell
[e-mail]
From: Boone, Ron [mailto:[e-mail]]
Sent: Friday, March 30, 2012 11:59 AM
To: James Cheshire
Cc: Basinger, Corey; Christine MacLaren
Subject: Winston Steel
Jim,
Attached are my comments to your response to the NOV we sent Winston Steel for their stormwater inspection. I've
also attached a copy of the current general permit, copies of the City of Winston-Salem's MS4 in their immediate area
(provided by the city's stormwater division), and some topos of the area. Please keep in mind that their ultimate
receiving stream is Salem Creek. Please DO NOT hesitate to call me if you have questions on addressing the remaining
issues. I'm more than happy to assist.
Regards,
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: ron.boone2ncdenr.gov
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

WINSTON STEEL & STAIR

WINSTON STEEL & STAIR

RESEARCh & ANA1yTICA1
LAbORATQRIES, INC.
AnafyticaVProcess Consulcations
16 March 2012
Mr. W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salem Regional Office
North Carolina Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street
Winston-Salem, North Carolina 27107
Subject: Response and Proposed Corrective Action Concerning Compliance
Evaluation Inspection and Notice of Violation — NOV -- 201 1 — I3C — 0077
NPDES General Stormwater Permit NCG030000 Certificate of Coverage
NCG030528 Winston Steel LLC. 216 Junia Avenue. Winston-Salem,
North Carolina Forsyth County
Dear Mr. Basinger:
In response to DENR's Notice of Violation concerning the above referenced
industrial facility currently identified as Winston -Steel, LLC, Research & Analytical
Laboratories, Inc. (RAL) has prepared the following response upon conclusion of their
site visit on 07 March 2012. It is important to note that RAL (Dennis R_ Herzing, P.E.
and Jatnes M. Cheshire) prepared the required Stonnwater Management Plan / SPCC
Plan for Winston -Steel in October of 2006. Enclosed is one (1) copy of both plans with
an updated Site Plan drawn to scale including location coordinates and elevation
measurements referenced to sea level. The Plans and Site Map were used to document
the Stormwater Management Plan requirements for this facility relative to the NPDES
General Storrilwater Permit (NCG03000) which expired on 31 August 2007.
The following responses / corrective actions have been prepared to address the
deficiencies identified in this most recent Notice of Violation by DENR in the same
chronological order as it appeared in the 28 February 2012 NOV Report.
l) The general location reap (GLM) does not show surface waters or the
k�
pp y ,i
l�
receiving stream...
d
Enclosed as Ii ii-1 ol'the SP3 / SPCC is an updated / revised Site Plan of GLM
shown in Appendix 2. The*61-M does not show. surface; .waters or tine
receiving stream because stortnwater runol dischar-es into a municipal' 5)t �
separate stone sewer maintained by the Ciiv of. inston-Salem. The GLM -'
does. however, show the storinwater-discharge outtalls (SDO) and accurate
\
P.C.La 1
. Box 473 • 106 Short Strtaet • Kernw�ers ills, Nnrth Carolina 27264 • 336-996-2841 •Fax 336.996-{}326
www.randatabs.com

2)
4)
latitudes and loiigittides for each SDO. It Was suspected, based upon the
"schematic" map ofthe site;shown,to RAL during the Site_Inspection.that .
DEN may not have been looking at a Site. Map or GLM prepared by RAL.
Tllis "schematic" appears to have inadvertently mislocated the SDO's in
relationship to an adjacent street. Junia Ave (see Enclosed. Schematic Map):
The Site Map (SM) does not delineate drainage areas clearly and does not
show all industrial activity areas...
The revised site map shown in Appendix- 2 of the SP3 /.SPCC Plan delineates
drainage areas clearly. for SDO's 001 and 002.sho�ving a runolYcoefficient of
0.75. It is estimated that approximately 90% of the property consisting of
buildiiig roof/ hardpan Unpaved par,kiiig ibt is.inod"erately impervious -to
stormwater runoff. Also included on t-he GLM is shown,,all industrial activity
areas such as finished product storage area and loading /:unloading areas:
There is a general statement that no spills have occurred at the facility in the
past three (3) years...
It has been recommended that a semiannual review audit be conducted based.
on the SP3 General errriit Actio hown on page ii and
Section 4.6 page
The SDO's were certified in November, 2008...
• ��t � ,z�_c_eti.Q. �� S i�b t
Itecommcridation,the same as item #3. i
5) There is no feasibility study in SP3 as required by Part 11, Section A.
Paragraph 2 of the general permit...
s anticipated that the required feasibility study.will be completed in.2012.
6) The Spill Prevention and Response Plan (SPRP) as required in Part 11, Section
A, Paragraph 3 of the general permit, should include a listing of emergency
contacts with telephone numbers...
These contacts are listed in'A�pendix 5 of the SPCC•Plan on^pages-4 and a:
Contacts not lncluded in Plan; lout i(lctiti.fied,in this DENR inspection will_ be
included in the Annual Review Update.. _ X` '4-
(�. S
7) The SP3 does not address Preventative Maintenance and Good H�ping
as required in Part 11, Section A. Paragraph 4...
This,informationis addresse(I_in the SP3 on page:3 section4.0 Best
Mang]g,ernent Practices {B11i1 1

8)
9)
10)
11)
12)
The SP3 does not address training as required by Part I1, Section A. Paragraph
5 of the general permit...
This infonnation,isaddressed in the SP3 on page,8,;Section,4.9 :Employee:
Traininu. The Employee Trainer desigmatedifor this facility was reported to
be Christine Mact_aren. PHR.
The SP3 does not address annual reviews of the SP3 as required in Part 11,
Section A, Paragraph 7...
This information is addressed _inthe,SP3 on page S, Section 4:8 Annual -Plan,
Review. .
Site inspections as required by Part 11, Section A, Paragraph 8, have not been
accomplished...
This information is addressed in the. SP3 on page 5, Section 4.6 Stonnwater
Discliar<-e Point -Inspection Pro`raph Section 4.3 Erosion / Sedimentation
Control Facility Inspection and Maintenance Program, and-Section,2-0 (pag
2) Pen -nit Re&irements / Comlili-bke.Activities. Docume6tation of this
activity through semi-annual audit and review is recommended for tHis facility
and includes both SP3 and,SPCC Plans;
The SP3 currently identifies two (2) SDO's, one in the southeast corner of the
site and the other in the southwest corner of the site...
We agree that the "schematic map" you are referring to'appears to.be
incorrect, however, RAL dici notiprgvide tliis map. 'Appendix 2 of the SP3
shows an updated.Site Plan which includes SDO's 001 `and 00i with location-
coordinatcs�a�nd-ro�uhd ev�itions The olijecMvitle
Mea
in�u t ese O's�
te west e evatiornpoint test stormwater
iinpactito the property.
Analytical and qualitative monitoring (AM & QM) records were reviewed...
Enclosed,is all of the AM J QM scinFannual data -required by section B & C
of the general pdrmit from 2007 throui 12011 with the.exception of TTO's.
There were no bcnch nark exceedances reported during this period.
13) According to Mr. Collins, once metal structures are built they are often wiped
down with a thinner...
Tlie testing of Total Toxic Or ianics (TTO),will ,commence during the next
stormwater sampling event
n�

Site Review
1) The containment pallet used to store 55-gallon drums of paint...
Th6 contaiiment pallet will he replaced -or repaiicd Within the next•30 days.
It is important to note that Winston -Steel has already begun the implementation of
correcting the deficiencies noted in DENR's Notice of Violation Report. Full compliance
with General Pen -tit is expected to be achieved within the next thirty (30) days.
Thank you for your thorough review and if you should have any further response,
please so advise.
Sincerely,
I -9% !; -
James M. Cheshire
President/CEO
Research & Analytical Laboratories, Inc.

Raw Storage (steel)
= M 90% impervious
(C=0.75)
= Containment Pallet
(551gal. Paint Drums)
Kerosene & Diesel
Tanks
outran oo 1 coordinates
36.07,1 4,-80.23529
M
outfall 002 coordinates
36.07149,-80.23614
** The numbers on the aerial map indicates g
elevations above sea level

STORMWATER POLLUTION PREVENTION
PLAN
SPILL PREVENTION AND RESPONSE PLAN
for
WINSTON STEEL LLC
Winston-Salem North Carolina Facility
Prepared for:
Winston Steel LLC
216 Junia Avenue
Winston-Salem, North Carolina
Prepared by:
Research & Analytical Laboratories, Inc.
106 Short Street
Kernersville, North Carolina 27284
(336)-996-2841
July 2006

TABLE of CONTENTS
Section
Title
Page
GENERAL PERMIT ACTION ITEM SUMMARY
ii
1.0
INTRODUCTION/HISTORICAL DEVELOPMENT
1
2.0
PERMIT REQUIREMENTS/COMPLIANCE ACTIVITIES
2
3.0
DISCHARGE SAMPLING AND ANALYSIS
3
4.0
BEST MANAGEMENT PRACTICES (BMP)
3
4.1
DESCRIPTION OF POTENTIAL POLLUTANT SOURCES
3
4.2
Spill Prevention and Response Plan
4
4.3
WASTE MANAGEMENT PROGRAM
4
4.4
ANNUAL ENVIRONMENTAL INSPECTIONS
5
4.5
EROSION/SEDIMENTATION CONTROL FACILITY
INSPECTION AND MAINTENANCE PROGRAM
5
4.6
STORMWATER DISCHARGE POINT INSPECTION PROGRAM
5
4.7
STORMWATER SAMPLING/ANALYSIS PROGRAM
6
TABLE -1
STORMWATER SAMPLING & ANALYTICAL REQUIREMENTS
7
4.8
ANNUAL PLAN REVIEW
8
4.9
EMPLOYEE TRAINING ti
8
APPENDIX 1
GENERAL PERMIT FOR STORMWATER
APPENDIX 2
SITE PLAN
APPENDIX 3
RECORDS
APPENDIX 4
FLOW CHARTS
APPENDIX 5
SPCC PLAN

GENERAL PERMIT ACTION ITEM SUMMARY
This summary sheet is provided for quick reference by those responsible for permit compliance activities. More detailed
discussions of these items are in the body of the plan.
ACTION ITEMS
o Record rain events on precipitation & inspection log -Appendix 3A.
o Inspect erosionisedimentation controls and stormwater discharge points in the spring and fall at a
minimum. Keep a record of inspections on precipitation & inspection log -Appendix 3A.
o Assure that follow-up actions to inspections are promptly completed. Record on precipitation &
inspection log - Appendix 3A and follow-up action log - Appendix 3B.
o Collect annual stormwater samples as described in Section 4.7. Record on analytical data log -
Appendix 3C. Attach standard laboratory chain of custody form when shipping samples to the
laboratory.
o Conduct visual monitoring of stormwater samples at least twice per year — once during the period Aril
through June and again during the period September through November. Record results of visual
sample monitoring on form provided in Appendix 3D.
o Comply with SPCC plan; record monthly tank inspections -Appendix 5.
o Employee training on Stormwater Management Plan and SPCC Plan is required at least annually. See
Section 4.9.
o Review and update the stormwater plan on an annual basis. Keep records of reviews on the form in
Appendix 3G.
SAMPLING NOTES
The following items are intended to provide guidance to Winston Steel LLC personnel in the event that they collect
samples in lieu of having them collected by laboratory personnel.
o Collect representative samples- avoid introduction of excess solids by not disturbing settled. sediments
or skimming floating solids from the surface at sampling location when filling sample bottle.
o Field analyze and record pH immediately (within 15 minutes) after collecting samples. Record pH on
Chain of Custody form before sending to laboratory.
o Caution! Sample containers for Oil & Grease analyses contain a small Quantity of acid to preserve
samples. Do not dump acid from bottles. Avoid personal contact with acid. Wear appropriate gloves
and eve protection while handling sample containers.
o Package with ice and ship samples to laboratory, for prompt delivery, as soon as possible after
collection. If samples are shipped on Friday for Saturday delivery, call the laboratory before shipping to
notify them of Saturday delivery. Alternatively, call the laboratory to arrange for sample pick-up. Contact
Mr. Jim Cheshire or Mr. Sid Champion at Research & Analytical Laboratories to request sampling kits or
to obtain further information. Ship samples with completed chain of custody form to:
Research & Analytical Laboratories, Inc.
106 Short Street
Kernersviile, NC 27284
PHONE: [phone]

SECTION 1.0 INTRODUCTIONMISTORICAL DEVELOPMENT
On November 16, 1990, the Environmental Protection Agency (EPA) issued regulations requiring National
Pollution Discharge Elimination System (NPDES) permits for stormwater discharges.
EPA has had the authority to control and regulate stormwater discharges that convey pollutants to the waters of
the United States, through point sources, since the enactment of the Clean Water Act in 1972. Historically,
however, the Agency chose not to exercise its authority to issue permits for most stormwater discharges. Instead,
the Agency concentrated its permitting efforts on discharges of process wastewaters from industrial facilities and
discharges from publicly owned treatment works (POTWs). As industrial and municipal wastewater discharges
have been brought increasingly under control, stormwater discharges containing pollutants have become the focal
point for EPA permitting efforts.
Two kinds of stormwater permits are issued under the NPDES program. One is the General permit which
provides coverage for a group of similar facilities. The other is the individual permit which is tailored to specifically
regulate a single facility. General permits for stormwater are issued in response to applications from industrial
groups and are tailored to the specific needs of the industry.
North Carolina sought authority to issue General Permits for Stormwater Discharges. EPA granted such authority
and North Carolina developed General Permit NCG030000 for Stormwater Discharges associated with activities
classified as Standard Industrial Classification (SIC) codes 335 (non-ferrous metal rolling, drawing and extruding),
3398 (heat treating of metal), 34 (fabricating of metal products), 36 (manufacturing of electronic equipment), 37
(manufacturing of transportation equipment), and 38 (manufacturing of measuring and analyzing instruments.
These various industries have expended considerable effort working with the State Division of Water Quality to
assure that the general permit meets, as much as possible, the specific needs of the industry.
Winston Steel LLC's Winston-Salem facility is covered under General Permit No. NCG 030000. The facility has
specifically been issued permit No. NCG190000. The Permit was renewed and revised by the state in 2002. The
current permit became effective 01 September 2002 and will expire on 31 August 2007. A copy of the permit is
provided in Appendix 1.

SECTION 2.0 PERMIT REQUIREMENTSICOMPLIANCE ACTIVITIES
The General Permit for stormwater discharges requires the following activities to assure compliance.
2.1 Preparation of this Stormwater Pollution Prevention Plan and implementation of the Plan.
2.2 Implementation of the Best Management Practices (BMP's) as defined in this plan.
2.3 Vehicles and equipment most be operated and maintained in a manner which prevents pollution
of surface or ground waters.
2.4 Secondary containment for above ground bulk storage tanks for petroleum and section 313
(SARA) water priority chemicals.
Note: Section 313 water priority chemicals include over 50 pages of hazardous chemicals. Most
are not stored in significant quantities or in bulk tanks at Winston Steel LLC Company.
Therefore, we are generally concerned with the secondary containment of petroleum
products_
2.5 Discharge sampling and analysis as described in this plan.
2.6 Monitoring and reporting as follows:
2.6.1 Regular inspection of all stormwater conveyance and control facilities
2.6.2 Regular inspection of all stormwater discharge points
2.6.3 Maintaining a record of the above inspections
2.6.4 Maintaining a log of sampling activities
2.6.5 Submittal of analytical data to the North Carolina Department of Environment and Natural
resources (NCDENR) for the first and last year of permit coverage unless cut-off
concentrations are not met in which case annual sample collection and submittal of data
will be required-
2

SECTION 3.0 DISCHARGE SAMPLING AND ANALYSIS
The General Permit requires sampling and analysis of point source discharges that fall in the following categories.
3.1 Stormwater discharges from plant areas where the stormwater• has contacted areas directly
related to manufacturing, processing, or raw materials storage. At the Winston Steel LLC facility,
these areas include all areas where outdoor painting or other work are conducted as well as areas
where materials and/or finished items are stored. In general, most plant areas other than the
office and parking lot are included,
SECTION 4.0 BEST MANAGEMENT PRACTICES (BIVIP)
Best Management Practices include:
Schedules of activities, prohibitions of practices, maintenance procedures, and other management
practices to prevent or reduce the pollution of waters of the United States. BMPs also include treatment
requirements, operation procedures, and practices to control plant site runoff, spillage or leaks, sludge or
waste disposal, or drainage from raw material storage_
The BMP's for Winston Steel LLC are comprised of the following policies, procedures and activities.
o A site specific spill prevention control and countermeasure plan (SPCC)
o An established above ground storage tank (AST) management program
o An established waste management program
o Erosion/sedimentation control facility inspection and maintenance program
o Stormwater discharge inspection program
o Stormwater sampling/analysis program
o Annual Stormwater Pollution Prevention Plan and SPCC Plan review
o Employee Training Program
4,1 Description of Potential Pollutant Sources
The primary potential sources of stormwater pollutants at Winston Steel LLC Company consist of material
storage areas, the outdoor painting area, the drum storage area, and AST fuel storage areas. These
areas are indicated on the Outfall Map in Appendix 2 of this plan.
4.1.1 Inventory of Exposed Materials
The Material Inventory Worksheet lists materials used, stored, or produced on -site along with their
potential to contribute pollutants to stormwater. The Significant Exposed Material Worksheet lists
materials that were exposed to stormwater in the last three years and/or are currently exposed.
4.1.2 Significant Spills and Leaks
The Significant Spills and Leaks Worksheet lists spills and leaks that have occurred at the facility
in the last three years, if any. The worksheet is also used to record future spills and leaks, if any.

The worksheets referred to above are contained in Appendix 3_ These worksheets were current as of the
time of preparation of the plan. They are also designed to be regularly updated in response to changes in
the operation or deficiencies noted during compliance inspections.
4.2 Spill Prevention and Response Plan (SPRP)
The spill prevention and response plan consists primarily of the Spill Prevention Control and
Countermeasure Plan (SPCC plan) which defines procedures for the prevention of spills of oils or
hazardous substances and response actions should such events ever occur. The SPCC plan for this
facility is in Appendix 5. Note that the plan includes a monthly inspection report which should be kept
current at all times.
There are three (3) potential sources of pollution associated with petroleum spills. Two (2) are located on
the southeast end of the manufacturing building which include the 55-gallon drum storage area with a
concrete slab and two (2) Above Ground Storage Tanks (AST's), consisting of one (1) 500 gal. diesel tank
and one (1) 500 gal kerosene tank both placed inside a 1,600 gallon standard septic tank_ There are also
typically 4 to 6 55 gallon drums of paint or associated materials in the painting area at any given time. At
present, the two (2) AST's are provided with secondary containment_ The drums in the painting area have
been provided with secondary containment.
SPRP TEAM: The following individuals are responsible for implementing the Spill Prevention and
Response Plan and the associated SPCC Plan.
Team Leader: Christine MacLaren, Human Resources Manager
The team leader is the primary person responsible for SPRP implementation.
Team Member: Steve Darnell, President
Team Member: Dave Collins, Purchasing
Team Member: Denton Bledsoe, Shop Supervisor
The team members are available to assist the team leader and will be responsible for
SPRP implementation in their respective areas of the plant or at times when the team
leader is not on site or is unavailable.
4.3 Waste Management Program
The Winston Steel LLC waste management program consists of policies and procedures regarding the
handling and disposal of solid and/or hazardous waste at the facility. The program is specifically designed
to assure regulatory compliance, to prevent on -site releases and to protect land and water resources.
4A Annual Environmental Compliance inspections
Winston Steel LLC conducts in-house inspections (i.e., self -auditing) on at least an annual basis to assure
compliance with environmental regulations including stormwater management_
4A.1 Annual Comprehensive Site Compliance Evaluation and Non-stormwater Discharge
Assessment Report and Certification.
4

The General Permit requires certification that stormwater outfalls have been evaluated for non
stormwater discharges. The form in Appendix 3-G is designed to record the results of annual
compliance inspections and contains the required certification.
4.5 Erosion/Sedimentation Control Facility Inspection and Maintenance Program
All stormwater conveyances and erosion and sedimentation control facilities at the site should be
inspected each spring and fall at a minimum. If possible, inspections should be conducted as soon as
possible after major storm events. These inspections can be brief, but should concentrate on identifying
any physical damage to control facilities requiring repair, required maintenance, or off -site sediment
transport. Required maintenance and/or corrective actions should be implemented promptly. The permit
requires keeping accurate records of these inspections, any problems noted, and corrective actions taken.
The Precipitation & Inspection Log and the Follow -Up. Action Log provided in Appendix 3 - Records are
used for this purpose. The logs should be kept current by making an entry after each inspection or follow-
up action. Records must be retained for at least 5 years.
4.6 Stormwater Discharge Point Inspection Program
All stormwater discharge points must be inspected once every spring (April through June) and once every
fall (September through November). Again, the inspections can be brief, but should be done in such a way
that outfall staining, off -site sediment transport, color, foam or sheens in the discharge are identified.
Corrective action must be taken promptly if any of the above are observed.
Accurate records of these inspections must also be kept, and the Precipitation & Inspection Log and
Fallow -Up Action Log are provided in Appendix 3 for that purpose. The logs should be kept current by
making an entry after each inspection or follow-up action.

4.7 Stormwater Sampling/Analysis Program
Refer to Table 1 (Page 7) for required sample frequency and analytical parameters. There are two (2)
appropriate sampling locations (outfalls) at the Winston Steel LLC facility.
Outfall No. Type of Discha[gee
001 Stormwater associated with industrial activities which is not
combined with process wastewater.
002 Same as above
Ouffall 001 & 002 are the points at which essentially all of the Stormwater associated with industrial activities
leaves the Winston Steel LLC property. This includes the outdoor painting area and AST'S. There are two catch
basins along the north side of the plant building which receive most of the runoff from areas impacted by industrial
activity including the outdoor painting area
There are other areas where minor discharges of stormwater leave the site. These discharges are not associated
with industrial activity.
The outfall locations are marked on the site plan in Appendix 2.

TABLE 1 - Stormwater Sampling & Analytical Requirements for Winston Steel LLC
NOTE: DUE TO SHORT ALLOWABLE HOLDING TIMES, SAMPLES SHOULD BE SHIPPED
FOR PROMPT DELIVERY TO THE LAB.
OUTFALL NO.
REQUIRED
PARAMETER
UNITS
CUT-OFF
CONCENTRATION
LIMIT
SAMPLING
FREQUENCY
& TYPE
ALLOWABLE
SAMPLE
HOLDING
TIME
NOTES
001
TOTAL FLOW
MG
NO LIMIT
ESTIMATE TOTAL
TOTAL
VOLUME OF THE
DISCHARGE OF
RAINFALL &
DISCHARGE DURING THE
STORMWATER
DURATION
STORM EVENT
ASSOCIATED WITH
LEAD, Total
Mg/L
0.033
YEARLY GRAB
6 mo.
ONE LITER GLASS
INDUSTRIAL
ACTIVITY
CONTAINER WITH ACID
OIL & GREASE
Mg/L
30
28 DAYS
PRESERVATIVE FOR OIL
& GREASE AND LEAD
ANALYSIS
TOTAL
Mg/L
100
7 DAYS
ONE 1 LITER
SUSPENDED
UNPRESERVED SAMPLE
SOLIDS
FOR TSS ANALYSIS.
STD.
>6.0 <9.0
FIELD
pH
UNITS
ANALYZE
WITHIN 15
MIN.
IF CUT-OFF
CONCENTRATIONS
SAMPLES MUST BE
ARE MET IN THE
YEAR,
FIRST YEAR,
COLLECTED WITHIN THE
SAMPUNGAND
FIRST 30 MINUTES OF
ANALYSIS IS NOT
THE START OF
REQUIRED AGAIN
DISCHARGE.
UNTIL THE LAST
YEAR OF THE
PERMIT
IN ADDITION TO THE ANALYTICAL TESTING IDENTIFIED IN THE ABOVE TABLE, VISUAL
MONITORING OF STORMWATER SAMPLES IS REQUIRED TWICE EACH YEAR. THE FIRST VISUAL
ANALYSIS MUST COINCIDE WITH THE FIRST SAMPLE EVENT AT STORMWATER OUTFALLS. THE
KEEPING OF ACCURATE RECORDS OF THESE ANALYSES IS REQUIRED AND RESULTS MUST BE
REPORTED. PLEASE REFER TO APPENDIX 3D FOR THE RECORD -KEEPING FORM TO BE USED.
VISUAL MONITORING MUST BE CONDUCTED TWICE PER YEAR REGARDLESS OF WHETHER
CUT-OFF CONCENTRATIONS ARE MET AT A PARTICULAR OUTFALL.

A log of sampling data must be maintained in accordance with the permit. A form for that purpose
is provided in Appendix 3 - Records.
In order to monitor representative storm events relative to collecting the annual samples for
discharge of stormwater associated with industrial activities, a rain gauge should be installed and
the duration and amount of each rain event should be recorded on the Precipitation & Inspection
Log provided in Appendix 3 - Records.
The total discharge for the storm event during which a sample is collected at outfalls 001 and 002
the duration of the storm event must be reported. The total flow discharged must also be reported.
Total flows have been estimated for given rainfall amounts by calculating the estimated discharge
from the site using the rational formula. These calculations take into account the area of the
property and the percentages of that area which are paved or occupied by buildings, stone
surfaced, grass, etc. A chart to convert total rainfall to total discharge at outfall 001 is provided in
Appendix 4.
4.8 Annual Plan Review
An annual review of this plan, including the SPCC Plan will be conducted to verify the accuracy of
the information contained in the plans and to assure that the controls specified in the Plans are
adequate and are being implemented.
4.9 Employee Training
Annual employee training sessions at the facility will include a discussion of this Stormwater
Pollution Prevention Plan and the SPCC Plan. More frequent training will be conducted when
necessitated by modifications or revisions of the Plans, by significant changes to the physical
stormwater pollution control devices at the facility, or in response to any spills or other incidents
which may occur.

APPENDIX 3A
STORMWATER POLLUTION PREVENTION PLAN
PRECIPITATION & INSPECTION LOG
This form is to be used to record the following information-
1. Rainfall records including date, total precipitation, and storm duration should be
recorded in the first three columns.
2. The fourth and fifth columns provide space to check whether a given storm even
meets the definition of a representative storm (i.e. total rainfall of 0.10 inch or more
and preceded by at least 72 hours of dry weather). A single storm event may
include up to 10 consecutive hours of no precipitation.
3. The sixth through ninth columns provide space to indicate when erosion and
sedimentation control facility and/or discharge point inspections are conducted.
4. Columns ten through thirteen are used to record whether the inspections recorded
in columns six through nine result in a need for follow-up action and, if so, when
and by whom the follow-up action was completed.

PLANT WTNSTON STEEL LLC Winston-Salem
YEAR
STORMWATER POLLUTION PREVENTION PLAN
PRECIPITATION & INSPECTION LOG
DATE
TOTAL
PRECIP, (IN.)
MEASURE TO
NEAREST
0,C5"
STORM
DURATION
(HR.)
REPRESENTATIVE STORM IS GREATER THAN 0.10 INCHES OF PRECIPITATION, AND IS
PRECEDED BY AT LEAST 72 HOURS DURING WHICH NO STORM WTH MORE THAN 0.10
INCHES OF PRECIPITATION OCCURS. A REPRESENTATIVE STORM CAN INCLUDE UP TO
10 HOURS OF DRY WEATHER. STORMWATER SAMPLES MUST BE COLLECTED
VIATHIN 30 MINUTES OF THE START OF THE DISCHARGE.
DURING ESS FACILITY INSPECTIONS LOOK FOR ANY
PHYSICAL DAMAGE AND EVIDENCE OF OFF -SITE
SEDIMENT TRANSPORT
REPRESENTATIVE
STORM?
EROSION AND
SECIMENTATION
CONTROL FACILITY
INSPECTION ?
DISCHARGE POINT
INSPECTION?OFF-SITE
CURING DISCHARGE POINT INSPECTIONS LOOK FOR
EVIDENCE OF STAINING, VISIBLE SHEEN, FOAM, AND
SEDIMENT TRANSPORT.
YES
NO
YES
NO
YES
NO
FOLLOW-UP ACTION
REQUIRED ?
(ENTER ON FOLLOW-UP
ACTION LOG)
FOLLOW-UP
COMPLETION
YES
NO
DATE
BY

APPENDIX 3B
STORMWATER POLLUTION PREVENTION PLAN
FOLLOW-UP ACTION LOG
This form is used in conjunction with the previous form to record in more detail the
problems identified during an inspection and the follow-up action taken to correct
those problems.

STORMWATER POLLUTION PREVENTION PLAN
FOLLOW-UP ACTION LOG
ORIGINAL FOLLOW-UP
INSPECTION ITEM DESCRIPTION OF PROBLEM & FOLLOW-UP ACTION FOLLOW-UP COMPLETION
DATE TAKEN COMPLETED BY DATE

APPENDIX 3C
STORMWATER POLLUTION PREVENTION PLAN
ANALYTICAL DATA LOG
This form is used to keep records of when samples were collected, when they were sent
to the laboratory, when the laboratory data report was received back from the lab, and
when the data was reported to DENR.
The date sample was collected, outfall number sampled, and date sample was sent to the
laboratory should be filled out immediately after sampling. The laboratory will send a copy
of the data report submitted to the state when the data is sent in to DENR. At that time,
the last two columns of the form showing when the data report was received and when it
was submitted by the laboratory to DENR should be filled in.

STORMWATER POLLUTION PREVENTION PLAN
ANALYTICAL DATA LOG
INSTRUCTIONS. SAMPLES SHOULD BE SHIPPED TO RESEARCH & ANALYTICAL LABORATORIES,
INC. (SEE GENERAL PERMIT ACTION ITEM SUMMARY). R&A WILL COMPLETE DMR REPORTS AND
SUBMIT TO THE STATE.
SAMPLE DATE I OUTFALL NO.(s) DATE SAMPLES DATE LAB RESULTS DATE DATA REPORTED
SAMPLED I SHIPPED TO LAB RECEIVED TO DENR

APPENDIX 3D
Visual Stormwater Sample Evaluation Record
This form is used to record the results of visual monitoring of stormwater samples which is
required to be conducted twice per year in accordance with the General Permit. Samples
should be collected and visually inspected for the presence of any color, odor, floating
solids, suspended solids, foam, or oil sheen. The clarity of the sample should also be
noted.
The results of these visual monitoring events are required to be submitted to the state.
Each .permittee is required to keep a record of the monitoring and have it available for
inspection.
This form should be completed each time visual monitoring is done .

Winston Steel LLC
Visual Stormwater Sample Evaluation Record
Plant
Outfall
No.
Date
Time
Visual Observations
Probable Source
Color
Odor
Clarity
Floating
Solids
Settled
Solids
Suspended
Solids
Foam
Oil
Sheen
Other

APPENDIX 3E
MATERIAL INVENTORY WORKSHEET
The material inventory worksheet is used to keep records of all materials used, produced or stored at the site. The form has space to
document the evaluation of the potential for each material to contribute pollutants to stormwater. This worksheet should be updated as
required, but at least once per year.

STORMWATER POLLUTION PREVENTION PLAN - MATERIAL INVENTORY WORKSHEET
INSTRUCTIONS LIST ALL MATERIALS USED, PRODLR'.ED OR STORED AT THE SITE. EVALUATE THE POTENTIAL FOR EACH MATFRIAI TO CONTRIBUTE
POLLUTANTS TO STORMINATER, LIST MATERIALS ON SIGNIFICANT EXPOSED MATERIAL WORKSHEET IF IT IS CURRENTLY, OR HAS BEEN IN THE LAST THREE
EARS, EXPOSED TO STORMWATER.
WORKSHFET
UPDATED BY.
TITLE:
DATE:
MATERIAL
USE I LOCATION
QUANTITY ON SITE
QUANTITY EXPOSED (CURRENTLY
OR 1N LAST 3 YEARS)
POTENTIAL FOR EXPOSURE TO STORMWATCR. {IF HIGH,
DESCRIBE)
PAST SIGNIFICANT
SPILL OR LEAK
USED
PRODUCED
STORED
YES
NO
I

APPENDIX 3F
SIGNIFICANT EXPOSED MATERIAL WORKSHEET
The Significant Exposed Material worksheet is used to keep records of all materials that are currently
exposed to stormwater, or have been exposed in the last three years. Based on the material inventory
worksheet, list the significant materials. Significant materials are those with the potential to contribute
pollutants to stormwater with which they come in contact. The form has space to document the material
management practices employed to minimize the risk of adverse impact on stormwater. This worksheet
should be updated as required, but at least once per year.

STORMWATER POLLUTION PREVENTION PLAN - SIGNIFICANT EXPOSED MATERIAL WORKSHEET
INSTRUCTIONS: BASED ON THE MATERIAL INVENTORY WORKSHEET, LIST THE SIGNIFICANT MATERIALS THAT ARE
CURRENTLY EXPOSED TO STORMWATER, OR HAVE BEEN EXPOSED IN THE LAST THREE YEARS. SIGNIFICANT
MATERIALS ARE THOSE WITH THE POTENTIAL TO CONTRIBUTE POLLUTANTS TO STORMWATER WITH WHICH THEY
COME IN CONTACT.
WORKSHEET
UPDATED BY:
TITLE:
DATE:
DESCRIPTION OF
SIGNIFICANT EXPOSED
MATERIAL
LOCATION
QUANTITY
EXPOSED
PERIOD OF
EXPOSURE
METHOD OF STORAGE OR
DISPOSAL
DESCRIPTION OF MATERIAL MANAGEMENT PRACTICES

APPENDIX 3G
ANNUAL COMPREHENSIVE SITE COMPLIANCE EVALUATION AND NOW
STORMWATER DISCHARGE ASSESSMENT REPORT AND CERTIFICATION
The Annual Comprehensive Site Compliance Evaluation and Non-Stormwater Discharge Assessment Report and Certification form is
used to keep records of the results of annual comprehensive site inspections. The upper half of the form is used to record the dates and
results of the site inspection and review of the adequacy of this Stormwater Pollution Prevention Plan. The lower half is used to record
the results of annual non-stormwater discharge assessments. These assessments should be made at each outfall to assure that no non-
stormwater flows (i.e. sewage or other waste discharges) are being discharged with stormwater. In most cases, the evaluation method
can be visual, however, if non-stormwater discharges are suspected more comprehensive methods such as smoke testing sewers, etc.
may be needed. This form should be updated as required, but at least once per year.

INSTRUCTIONS: RECORD BELOW THE RESULTS OF ANNUAL COMPLIANCE INSPECTIONS AND ANY REQUIRED MODIFICATIONS TO THE STORMWATER POLLUTION
PREVENTION PLAN INCLUDING THE VARIOUS WORKSHEETS IN THE PLAN. AS PART OF THE ANNUAL INSPECTION, A NON-STORMWATER DISCHARGE ASSESSMENT SHOULD
BE CONDUCTED TO DETERMINE THAT NO NON-STORMWATER DISCHARGES ARE OCCURRING AT STORMWATER OUTFALLS.
INSPE
CTION
DATE
DESCRIPTION OF DEFICIENCIES
NOTED IN FIELD INSPECTION OF
STORMWATER POLLUTION
PREVENTION DEVICES, IF ANY
ADEQUACY OR REQUIRED MODIFICATIONS TO STORMWATER POLLUTION PREVENTION PLAN
CORRECTIVE MEASURES TAKEN
BY
SITE MAP
UPDATED
SAMPLING &
MONITORING
PROGRAM IN
COMPLIANCE
MATERIALS
INVENTORY
WORKSHEET
UPDATED
SIGNIFICANT
EXPOSED MATERIAL
WORKSHEET UPDATED
SIGNIFICANT SPILLS AND
LEAKS WORKSHEET
UPDATED
BY:
DATE:
BY:
DATE;
BY:
DATE:
RESULTS OF ANNUAL NON-STORMWATER DISCHARGE ASSESSMENT
DATE
OUTFALL DIRECTLY OBSERVED
EVALUATION
METHOD
DESCRIBE RESULTS OF TEST FOR NON-STORMWATER
DISCHARGE
IDENTIFY POTENTIAL
SOURCES
PERSON CONDUCTING
ASSESSMENT
CERTIFICATION: I, (RESPONSIBLE CORPORATE OFFICIAL), CERTIFY UNDER PENALTY OF LAW THAT THIS
DOCUMENT AND ALL ATTACHMENTS WERE PREPARED UNDER MY DIRECTION OR SUPERVISION IN ACCORDANCE WITH A SYSTEM DESIGNED TO ASSURE THAT QUALIFIED
PERSONNEL PROPERLY GATHER AND EVALUATE THE INFORMATION SUBMITTED. BASED ON MY INQUIRY OF THE PERSON OR PERSONS WHO MANAGE THE SYSTEM OR
HOSE PERSONS DIRECTLY RESPONSIBLE FOR GATHERING THE INFORMATION, THE INFORMATION SUBMITTED IS, TO THE BEST OF MY KNOWLEDGE AND BELIEF, TRUE,
ACCURATE, AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLUDING THE POSSIBILITY OF FINE AND
IMPRISONMENT FOR KNOWING VIOLATIONS.
NAME & OFFICIAL
TITLE
PHONE: ( )
SIGNATURE:
DATE SIGNED:

FLOWCHART - OUTFALL 001 Winston Steel LLC
TOTAL DISCHARGES CALCULATED BASED ON A 10.29 ACRE DRAINAGE_ AREA USING AN A VERAGE
R Ui'OFF COEFFICIENT OF 0. 75.
RAINFALL
INCHES
TOTAL DISCHARGE
MG
0.1
0.0207
0.15
0.0311
0.20
0.0415
0.25
0.0518
0.30
0.0622
0.35
0.0726
0.40
0.0830
0.45
0.0933
0.50
0.1037
0.55
0.1141
0.60
0.1244
0.65
0.1348
Q.70
0.1452
0.75
0.1555
0.80
0.1659
Q85
0.1763
0.90
0.1867
0.95
0.1970
1.0
0.2074
1.1
0.2281
1.2
0.2489
1.3
0.2696
1.4
0.2904
1.5
0.3111
1.6
0.3318
1.7
0.3526
1.8
0.3733
1.9
0.3941
2.0
0.4148

WINSTON STEEL & STAIR

Corey,
I reviewed Mr. Cheshire's response to the NOV we sent for the inspection at Winston Steel. Here are my
comments to his responses listed in the same order that Mr. Cheshire addresses them in his letter,
which is the same way they are listed in the original NOV:
1.
a. The GLM and the SM at two different requirements of the SP3 and each has specific
required items. They appear to believe that they are one in the same.
b. Mr. Cheshire states that the GLM does not show the surface waters or the receiving
stream because the discharge is to the Winston Salem MS4, however, showing adjacent
surface waters, especially the ultimate receiving stream, is a requirement of the GLM
regardless of whether initial discharge goes to the MS4. Besides, they should know
where in the MS4 their discharge eventually_enters the actual stream.
C. The GLM still does not show whether the receiving waters are impaired.
d. Neither the GLM nor the SM show ALL SDOs with accurate lats/longs. Where are at least
three other drop inlets on the property, in addition to the two they have identified as
SDOs, that are considered SDOs, as well as two curb inlets on the north side of the
building along Junia Avenue that probably also receive drainage from the site. All SDOs
need to be identified and monitored and if the facility wishes to apply for representative
outfall status (ROS) at some point in the future, we'll probably be able to agree to a
reduction of AM monitored SDOs. Please refer to the attached map of the city of
Winston-Salem's MS4 in that area.
►9
a. With the additional five SDOs, the drainage areas are NOT clearly delineated.
b. Mr. Cheshire indicates that approximately 90 percent of the site is impervious. This
should be broken down into the separate drainage areas that correspond to each SDO.
C. I was told during the inspection that the west end of the building is the raw product
storage area and the east end is the finished product storage area. Mr. Cheshire states
that finished product areas and loading/unloading areas are identified on the map,
however, unless I'm just missing it, the only things identified on the map are the raw
product storage (which according to what I was told in the inspection is inaccurate),
kerosene and diesel tanks, and containment pallet. Loading/unloading areas, disposal
areas, etc. are not identified, although, if all that was shown on the small SM that they
have, it would become quite busy and difficult to read. Suggest a larger site map.
3.
Mr. Cheshire states that it has been recommended that a semi-annual review audit be
conducted based on the SP3 — General Permit Action Item Summary shown on page ii
and Section 4.6 page S. I've reviewed both sections of the SP3 that he mentions above
and neither mention anything about the requirement to update the spill list annually,
which is what was initially written up.
4.
a. Again, Mr. Cheshire states that it has been recommended that a semi-annual review
audit be conducted based on the SP3 — General Permit Action Item Summary shown on
page ii and Section 4.6 page S. I've reviewed both sections of the SP3 that he mentions
above and neither mention anything about the requirement to recertify the SDOs
annually, which is what was initially written up.
5.

a. OK
b.
a. I reviewed the appendices of the SPCC plan and did not find any such listing. The entities
I suggested them to list in the SPRP(S133) are not listed anywhere that I can see.
Although this is NOT a specific requirement, it is highly recommended.
7. a. The specific Preventative Maintenance/Good Housekeeping Program is not directly
addressed in section 4.0 (page 3) of the SP3 as Mr. Cheshire indicates, at least not to the
extent that this inspector believes it should be.
8.
N
IN
11.
12.
a. OK — but no training has been accomplished.
a. OK — but annual reviews are not being accomplished.
a. None of the three sections of the SP3 that Mr. Cheshire mentions, sufficiently address
the Facility Inspection Program as this inspector believes the permit requires it to. This is
intended to be an OVERALL site inspection. No comprehensive site inspections have
been done or recorded. This item kind of goes hand in hand with item 7, above.
a. Mr. Cheshire's response indicates that they granted themselves ROS, given the fact that
there are at least 5 other potential SDOs, and Mr. Cheshire states, "the objective in
selecting these SDOs was determined by the lowest elevation point with the greatest
stormwater impact to the property." All SDOs must be identified and monitoring and
DWQ grants ROS if so warranted.
a. Did not review AM/QM records, but these records need to be kept on site at all times
and AM/QM need to be accomplished according to the new permit requirements, not
the old permit — refer to #14 below.
13.
a. Suggest they develop the Solvent Management Plan rather than test for TTOs; it's a
much less expensive option.
14. As a general statement, Mr. Cheshire admits that the SP3 was written based on the
previous edition of the permit. The current SP3 even talks about the "annual
stormwater samples", while the new permit requires semi-annual sampling. It is highly
suggested that the new permit being reviewed in detail and the SP3 rewritten to
address all the requirements of the new permit.

RESEAR& & ANA�YY&A[
' LAbt) - -- R1E5, iNC:
' AhalptaVProcess Consultations
16 March 2012
Mr. W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salem Regional Office
North Carolina Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street
Winston-Salem, North Carolina 27107
Subject: Response and Proposed Corrective Action Concerning Compliance
Evaluation Inspection and, Notice -of Violation — NOV — 2011 -- PC — 0077
NPDES General Stormwater Permit NCG030000 Certificate of Coverage
NCG030528,Wlnsf6n Steel LL-C, 216 Junia Avenue; Winston-Salem,
North Carolina Fofsyth County
Dear Mr. Basinger:
In response to DENR's Notice of Violation concerning the above referenced.
industrial facility.currently identified as,Winston-Steel, LLC, Research & Analytical
Laboratories, Inc. (RAL) has prepared the following.response upon conclusion of their
site visit on 07 March 2012_ It is important to note that RAL (Dennis R. Herzing, P.E.
and James M. Cheshire) prepared the -required Stormwater Management Plan / SPCC
Plan for Winston -Steel in October of 2006. Enclosed is one (1) copy of both plans with
an updated Site Plan drawn to scale including location coordinates and elevation
tricasureinents referenced to sea level. The Plans and Site Map were, used to document
the Stormwater. Management Plan requirements for this facility relative to the NP_ DES
General Stormwater Permit (NCG03000) which -expired on 31. August 2007.
The following -responses / corrective actions have been prepared to address the
deficiencies identified in this most recent Notice of Violation by DENR in the same
chronological order as it appeared in.the 28 February 2012 NOV Report.
1) The general location map (GLM) does not show surface waters or the
receiving stream...
Enclosed as part of tiir SP3 / SPCC is an updated / f6vise&Sitc�Plan or GLM.
s own•in'Apppndix-2. The GL M clncs_not show su face%%Iatcrs o`r thc'
receiving stream because storinwater.runot discharges into'a,munieipal
separate,storm sewer- -`maintained b ,tlic�City € t'tWinston--S_ aicm. ' TKcc'GLM
does: however, showithc.stormwater-- iseharge outfalls (SD and,accurate ,
FA Box 473 • 'i QE;!Shorc Street Kernersville North baralina•27264 ! 336-9964841 !Fax 336-99&0328
- . - www.randalabs.com • .

,rlatitudes �and bngitiides,for each SDOi It:�vas suspected: iiased.u}5on'the"
schematic' map of thc;srtc;shown,to,RAL during the�Siteanspcctiorialiat
QENR may notihave been,Iooking ava Site Map or GLM prepared b`y RAIL.
rTliis "sehemati6l appears tothave:rnadvertcifitlydislocated the SDO's in
Trelationship to:an adjpcent,street, Junia Ave (see Enclosed. Schematic,Map)1
2) The Site Map (SM) does not delineate drainage areas clearly and does not
show all industrial activity areas...
Thexcvised,site map -.shown in Appendix`.2 of,the�SP:3,/SP.C6 Plan'd`elineates�
drainage areas clearly: foe S.D'U ''6 aiiid 002'sholvin. a iif66ff-coeffrcid it of,
' 0.75: It is-estimatcd:that approximately;90%o of the property consisting of
I liuiIdiiig.roof/ hariil an urEpaved;parkiiig lot is.inoderately impervious to
'stormwater;runoff. ;Also inc4u�ded on,the,GLM,is,shown' l'jndust.ial activity
areas such:as'fin isl�c&product.,storage-1area and loading hunIoading areas:
3) There is a general statement that no spills have occurred at;the,facility in the
past three (3) years...
1 I0has been'recomniended that,:.a:semi=annuait review audit be conducted -based,
,on th SP3'-6ineral�Perin�i'Ackioi�;[tcm Sumrriizi}+rshoi�n'on page,ii and
ESection-4'.6
4) The SDO's were certified in November, 2008...
Ace6minendation,tlie same;as,,item.43:
5) There;is no feasibility study in SP3 as required by Part 1I, Section A.
Paragraph 2 of the general permit...
ItJs ariiicipated,tliat,the i quiiedle6a'siliiiity;study;will. b,e,completed;ih 2012.
5) The Spill Prevention and Response Plan (SPRP) as required in Part 11, Section
A, Paragraph 3 of the general permit, should include a listing of emergency
contacts with telephone numbers...
M, iese contacts -are. listed+in'Appendix .57of tljc SPCCjPlan ork`pages'4 :and 5;
C- riiacts not;inclt;d6d,;in Plan; but�identifred;iir:tlii's OENR�i_iispectii?ri will;be
included'in the.Annual Review, Update.
7) The. SP3 does not address Preventative Maintenance and Good Housekeeping
as'required'in Part 11, Section A, Paragraph 4...
' T_ his�informationi is addressed! in' thc•SM),on,page�3 sectionA-6 Best
Maiiagement` Pmcticc's:(BMP.).,

8) The SP3 does not address training as required by Part II. -Section A, Paragraph
5 of the general pei mit.. .
Ttiis inforti ationtis`addressed in,the_SP3 on-page:8, Section" .9, tri'"o ee;
Trainine* The Employee Trainer• designated 1foi.;his facility:%yasreported, tos
be Christine"MacLaren. PHR. _
9) The SP3 does not address annual reviews of the SP3 as required in Part 11,
Section A, Paragraph 7...
'This information;is addressed'iil ti e,SP3'orG.page:$, Section 4 S Annual'Plan
Review.. `
10) Site inspections as required by Part ❑, Section A,_ Paragraph 8, have not been -
accomplished...
This information is addfesse&ih,`the-SP3 .on,page 5;:Sec[ionA6;Stormwat&
Di'scl3are'P6int:Inspecto'ii l'rorainS"ec[ion 4:5 Erosion.) Sedimentation`
,Conir©L FacilitYlnspection and Maintenakd Pr_ogam land:Sectibn;2:0`(page
2} Perti-iit.Re uifeitients /,Cb "Iiarice.Acti�itics. a,Dociarri-d itatibn of this
iactiviiy`through'serrii;annual;audi't.and'reV ew;is recommended for`tlii's,tacility
-an d'includes`b-oth:'SP3,and-SpCC- Plans,
11) The SP3 currently id_entiiie's two (2) SDO's, one in the southeast corner of the
site and the other -in the southwest crime'] of the site...
We. agtee;that the;'`schematic map; you'are rrferriitg__u appears to;be.
inco-rrect,. However; IWWL _did not.;pcevide; this snap: 'Appendix 2 df the SP3
shows an updated,Site-Plan-,whicli;includes:SDO°s 0011arid 002,witli,locaiiont
{ caordiiiates acid ground elevations: The obi6dtNe iti selecting these SDO?s
was:determined by.tli tlowest.dlevationipo"irit_vVith the.greatest stormvvater
iffy ctlto'thd-property'.
12) Analytical and qualitative monitoring (AM. & QM) records were reviewed...
Encfosediis:all of;ihe•AM '/ QM,semi-annual data!required by:sectinn>B `&;C
of the geiieial pertrit°frcitii �007ithrougli 20.1'.l %with thC' ,exception of�TTO's.
'There were iio benchmark exceedances reported duiitig this'period
13) According, to Mr. Collins, once metal structures. are built they are often wiped
down with a thinner...
coneneetThe tesiinaof;TotalToxicObicj-17-b),VMImirrls
stormwater'sampl ng event, "

Site Review
1) The containment.pallet used to store 55-gallon drums of paint...
Tlie;containment pallet;wiII be replaced'.or.re.paired WitiiiiYtlie7nekt130 dayst
It is important to note'that Winston -Steel has already begun the implementation of
correcting the deficiencies,NR noted in DE's Notice'of,Violation Report. Full compliance
with General Permit is expected to be achieved --within the next thirty (3.0) days.
Thank you for your thorough review and if you should have any further response,
please so advise.
Sincerely,
/_..
James M. Cheshire
President/CEO
Research & Analytical Laboratories, Inc.

�j3/�z
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Chuck Wakild, P.E. Dee Freeman
Governor Director Secretary
February 28, 2012
Winston Steel and Stair
Attn: Christine MacLaren
1947 Union Cross Road
Winston-Salem, NC 27107
Subject: Compliance Evaluation Inspection & Notice of Violation
NOV-2011-PC-0077
NPDES General Stormwater Permit NCGO30000
Certificate of Coverage NCG030528
Winston Steel and Stair, Junia Avenue Plant
Forsyth County
Dear Ms. MacLaren:
Ron Boone of the Winston-Salem Regional Office of the NC Division of Water Quality (DWQ or the
Division) conducted a compliance evaluation inspection (CEI) at the subject facility on February 28, 2012.
Your assistance and cooperation, as well as that of Mr. Dave Collins, was greatly appreciated. An- inspection
checklist is attached for your records and the inspection findings are summarized below.
The facility is located at 216 Junia Avenue, in Winston-Salem, Forsyth County, North Carolina, at
approximate coordinates 36.071345',-80.235884*. Stormwater related to industrial activity is discharged from
the site to Salem Creek, which is currently classified as a Class C water located in the Yadkin Pee -Dee River
Basin.
Documentation & Monitoring Review
The Stormwater Pollution Prevention Plan (SP3) and monitoring activities were reviewed. It appears
that the SP3 was written according to the previous issuance of the general permit, although the previous permit
expired in 2007 and the SP3 appears to have been written in 2008. Several deficiencies were identified as
enumerated below:
The general location map (GLM) does not show surface waters or the receiving stream. Furthermore, it
does not show the stormwater discharge outfalls (SDO) and accurate latitudes and longitudes for each
SDO. Lastly the GLM does not specify whether the receiving stream is impaired. Please refer to Part
11, Section A, Paragraph 1(a) of the general permit.
2. The site map (SM) does not delineate drainage areas clearly and does not indicate the percentage of
each drainage area that it impervious. Furthermore, the SM does not show all industrial activity areas,
such as disposal areas, finished product storage area, and loading/unloading areas. Please refer to
Part II, Section A, Paragraph 1(c) of the general permit. Note: There is a statement in the SP3 that
indicates that 90% of the total site is impervious.
North Carolina Division of Water Quafity, Winston-Salem Regional office
Locations: 585 Waughtown St. Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service:1-877-M-6748 NorthCarolina
Internet: www.newaterquality,org ;/ ►` ']�'"`Jatunq 111
An Equal Opportunity 1 Affirmative Action Employer

Winston Steel and Stair
Attn: Christine MacLaren
Compliance Evaluation Inspection, NCG030528
Winston Steel & Stair Junia Avenue Plant
2129/2012, Page 2 of 3
3. There is a general statement in the SP3 that no spills have occurred at the facility in the past three
years. However, the spills list, as required in Part 11, Section A, Paragraph 1(d) and Part II, Section A,
Paragraph 7, of the general permit, has not been updated annually.
4. The SDOs were certified in November, 2008. However, the has not been any annual recertifications as
required by Part II, Section A, Paragraph 1(e) and Part II, Section A, Paragraph 7 of the general permit.
5. There is no feasibility study in the SP3 as required by Part II, Section A, Paragraph 2(a) of the general
permit.
6. The Spill Prevention and Response Plan (SPRP), as required in Part 11, Section A, Paragraph 3 of the
general permit, should include a listing of emergency contacts with telephone numbers. Such contacts
should include but are not limited to the following:
a. Local Fire Department and/or HAZMAT;
b. Local Police Department and medical services;
c. Local and/or county environmental and public health services;
d. Environmental cleanup contractors;
e. NC Division of Water Quality (this office); and
f. U.S. EPA, National Response Center
7. The SP3 does not address Preventative Maintenance and Good Housekeeping as required in Part 11,
Section A, Paragraph 4.
8. The SP3 does not address training as required by Part 11, Section A, Paragraph 5 of the general permit,
and no annual training has been accomplished.
9. The SP3 does not address annual reviews of the SP3 as required in Part 11, Section A, Paragraph 7,
and no annual SP3 reviews have been accomplished.
10. Site inspections as required by Part II, Section A, Paragraph 8, have not been accomplished.
11. The SP3 currently identifies two SDOs, one in the southeast corner of the site and the other in the
southwest corner of the site. However, after close onsite examination by Mr. Boone and Mr. Collins
during the inspection, both of these points appear to be at the highest points of the site; not exactly an
ideal representative location for an SDO. There are several stormwater drop inlets located throughout
the site as well as three curb inlets on Junia Avenue just in front of the site, which all tie into the City of
Winston-Salem's storm sewer system. Mr. Boone has acquired drawings of the stormwater
infrastructure in the area from the City to try to determine what points on the property would act as the
best, or most representative SDOs for sampling purposes. However, you should find out as soon as
possible at what locations your sampling laboratory is currently taking the stormwater samples. Once
this is known, we can work better with you in determining the correct SDOs. Nevertheless, the SDOs
currently identified in the SP3 appear to be incorrect.
12. Analytical and qualitative monitoring (AM & QM) records were reviewed. Only one AM/QM event was
conducted in 2007 and 2008, no AM/QM events were conducted during 2009 and 2010, and two
AM/QM events were conducted in 2011. This does not meet the requirements specified in Part 11,
Sections B & C of the general permit, which requires that AM/QM be conducted at each SDO twice per
year, with a minimum of 60 days separating each AM/QM event. It is noted that no benchmark
exceedences have occurred during any of the AM/QM events that were conducted.
t

`f Winston Steel and Stair
Attn: Christine MacLaren
Compliance Evaluation Inspection, NCG030528
Winston Steel & Stair Junia Avenue Plant
2/2912012, Page 3 of 3
13. According to Mr. Collins, once metal structures are built they are often wiped down with a thinner to
clean them and then painted. This process fits within the definition of metal finishing. As such, Winston
Steel is required to test the stormwater for Total Toxic Organics (TTO), as required in Part II, Section B
of the general permit. Winston Steel has yet to test their stormwater for TTO.
Site Review
The site was fairly clean and well maintained. Mr. Boone noted only the following minor deficiency:
1. The containment pallet used to store 55-gallon drums of paint and located on the east end of the facility
appears to have been run over, crushing part of one of the side walls of the containment pallet. This
containment pallet should be repaired or replaced.
Please correct all deficiencies noted above as soon as practical. Please reply in writing to this letter
within 30 days of receiving it. Your reply should provide proposed corrective actions with implementation
schedules for each of the deficiencies enumerated above. Please note that violations of the NCG030000
general permit are subject to civil penalty assessments not to exceed $25,000 per day, per violation. Your
written response will be considered in deciding whether any further action should be taken.
Should you have any questions regarding the permit, the inspection, or this letter, please do not
hesitate to contact Mr. Boone or me at [phone].
Sincerely,
W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments:
1. BIMS Inspection Checklist
cc: SWP — WSRO
Central Files
Stormwater Permitting Unit

if
Compliance Inspection Report
Permit: NCG030528 Effective: 02/17/12 Expiration: 10/31/12 Owner: Winston Steel & Stair
SOC: Effective: Expiration: Facility: Winston Steel & Stair
County: Forsyth 216 Junia Ave
Region: Winston-Salem
Winston Salem NC 27127
Contact Person: Christine Maclaren Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/28/2012 Entry Time: 09:00 AM Exit Time: 11:30 AM
Primary Inspector: Ron Boone J Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant i Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCGO30528 Owner - Facility: Winston Steel 8 Stair
Inspection Date: 02/28/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Please refer to the attached inspection summary/NOV letter.
Page: 2

Permit: NCG030528 Owner • Facility: Winston Steel 8 Stair
Inspection Date: 02/28/2012 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?
■
n
n
Cl
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
n
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
Cl
■
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
E
❑
n
# Has the facility evaluated feasible alternatives to current practices?
❑
■
❑
❑
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
0
❑
❑
❑
# 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?
n
®
n
n
# Dees 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?
❑
■
Cl
n
Has the Stormwater Pollution Prevention Plan been implemented?
❑
®❑
❑
Comment: Please refer to the attached inspection summary/NOV letter.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
■
❑
❑
Comment: Please refer to the attached inspection summary/NOV letter.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
n
e
❑
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
®❑
❑
Comment: Please refer to the attached inspection summary/NOV letter.
Permit and Qutfalls
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?
®❑
n
0
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
❑
E
0
❑
Comment: Please refer to the attached inspection summary/NOV letter.
Page: 3

AJ
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves perdue Chao+es Waki!d, P. E. Dee Freeman
Governor Director Secretary
N.C.Depf; i)fENR I
February 17, 2012 .2,3 IN?
Winston-Salem
Ms. Christine Mac Laren Regional Offidlil
Winston Steel LLC
1947 Union Cross Road
Winston-Salem, NC 27107
Subject: NPDES Stormwater Permit'Coverage Renewal
Winston Steel LLC
COC Number NCG030528
Forsyth County
Dear Permittee: � I
—c-
In response to your renewal application for continued coverage under Stomwater General Permit
NCG030000 received February 14, 2012; the Division of Water Quality (DWQ) is forwarding herewith
the reissued Certificate of Coverage and stormwater General Permit. This permit is reissued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15,
2007 (or as subsequently amended.)
The following information is included with your permit package:
• A new Certificate of Coverage
• A copy of the stormwater General Permit
• A copy of a Technical Bulletin for the General Permit
• Five copies of the Discharge Monitoring Report (DMR) Form
• Five copies of the Annual Discharge Monitoring Report Form (if applicable)
• Five copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater only, and it specifies your obligations with
respect to stormwater discharge controls, management, monitoring, and record keeping. Please review
the new permit to familiarize yourself with all changes in the reissued permit. Significant changes to the
General Permit are outlined in the attached Technical Bulletin.
Your coverage under the General Permit is transferable only through the specific action of DWQ.
This permit does not affect the legal requirements to obtain other permits which may be required by
DENR, nor does it relieve the permittee from responsibility for compliance with any other applicable
federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 91 M07-64921 Customer Service: 1-877-623-6748
Internet: www.ncwaterguality.ora One
An Equal OpportunilylAfWativeAclioo Employer NorthCarolina
Naturally

0-
If you have any questions regarding this permit package please contact the DWQ Storrnwater Permitting
Unit at 919-807=6300.
Sincerely,
URIG1N& SIGNED M
KEN PICKLE
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files ;
Winston-Salem Regional Office, Surface Water Protection Section Supervisor

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030528
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. I, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended.
Winston Steel LLC
is hereby authorized to discharge stormwater from a facility located at:
Winston Steel LLC
216 Junia Avenue
Winston-Salem
Forsyth County
to receiving waters designated as Salem Creek, a class C waterbody in'the Yadkin -Pee Dee
River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, 1I, 111, IV, V. and VI of the General Permit as attached.
This certificate of coverage shall become effective February 17, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day February 17, 2012.
MINAL SIGNED M
KEN PICKLE
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Coverage
0
Renewal Application Form
National Pollutant Discharge Elimination System Certificate of Coverage Number
Stormwater General Permit -NCG0J0000 NCG030528
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/ additions as necessary in the space provided to the right of the current information.
Owner Information I ,
Owner / Organization Name: Winston Stee &�Stait jyt 4ij ki c QP�
Owner Contact: (2 Y\['i S+1' %-1 e fY1 Q CC La (-en
Mailing Address: 2�9, n`'iJCAve q'cj 7 non fo
W nsto' Sal m, N 2.720� 1�1�nSFan �ct1QW1 NL Si.-7
�A.�. —
Phone Number: -7 88, (n 151
Fax Number: 33C0f 7 5, U
E-mail address: h r LU I ri an nt-e_2j o Com
Facility 10forMatioa
r r `
A
Facility Name: Winston Steel':&entail ti y15i Cn LC
Facility Physical Address: Z_19 ]uni A e d l U rj i GL H V-9
N2710 �u= nit aY, g,4, Nc a 7,a 7
Facility Contact:
Mailing Address: 17LI2 UrvorN[3�>S [
NL. 1
Phone Number:
Fax Number:
E-mail address:
Permit Information
Permit Contact: FEB 1 6 2012 LIC1.4(10_0
Mailing Address: WE DENR•WATER QUALfTY YLJ YU11 -
DSAN71MD STORMWATER BP,ANCH
Phone Number:
Fax Number:
E-mail address:
Discharge YnfoiMation
Receiving Stream: IC
Stream Class: {
Basin: lfaif'Ltn'a•Pr�,eei€3e River Basin
Sub -Basin; 3-07
Number of Outfalls:
Facility/Actlyity Channel Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
l 0 0ko-' jeb
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true. complete and accurate. _._.
Signa
U\ l Ski 1 l C VA C,C O'eA
Print or type name of person signing above �'►w yw...
Please return this completed renewal application form to:
Mc.�_'Ua R w f z
Date ahLar
&MOA1
Title
SW General Permit Coverage Renewal
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

04 WALe, Permit Coverage
a� Renewal ARplication Form
National Pollutant Discharge Elimination System
Stormwater General Permit NCG030000
Certificate of Coverage Number
NCGO3.0S28
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/ additions as necessary in the space provided to the right of the current information.
Owner Information
Owner / Organization Name: WinstoTSteel & Stair,
Owner Contact:
f(Yj Q C. LQ+r 2Kt
Mailing Address:
219 ]unia A e
1q9i Unoyl 'rnO '
W,nst_ on Sal m_, NG Z7106
Uns�oyl Ca ��'�1 Nc_ A 7 i o i
Phone Number:
336=788-8835 Ext?
, -7 86?. (p 151
Fax Number:
33t0, 7 S, U
E-mail address:
U) i riS OY1 S{f c7I a Com
Facility Information
Facility Name:
Winston Steel:& Staiy
Facility Physical Address:
219 J unl i
I G J U rl (,L R V Q
Winston—Sa m, NC 2 110.6
S vvi tic 0-71
Facility Contact:
Mailing Address:
47 Uniorx ois f
\N 5 vn, NC_ ra 7 107
Phone Number:
Fax Number:
E-mail address:
Permit Information
Permit Contact:
�1fi S�r fi2 (r nQJ-4(Q+7
Mailing Address:
C3i,J'YC.R t�
Phone Number:
OLVOILCLO
Fax Number:- .
-
E-mail address:
Discharge Information
Receiving Stream:
Salem:Creeka�MiddW Fork=MuddyCr6_ek5
Stream Class:
C
Basin:
Y, . dKj! -Pee:Dde River Basin
Sub -Basin:
03_07:_0.4
Number of Outfails:
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
- `No (2han.w
CERTIFICATION
I certify, that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such inform tion is tr e, comp) and ae urate. r
Signature , ` ' ' _ Date o7 r j laor�
4.1�P.r�'
Print or type name of person signing above Title U �@�aUlm
SW General Permit Coverage Renewal jj
Please return this completed renewal application form to: Stormwater Permitting Unit U
1617 Mail Service Center FEB 1 3 2012
Raleigh, North Carolina 27699-1617
DENR - WATER QUALITY
ANOSAND STORMWWATER BRANCH

Elaine F. ,filar shin
SECRI:'I'ARY OF STATE
December 28, 2011
State of North Carolina
Department of the Secretary of State CheriECT tROFC
DIRECTQR QI° Ct]RPQRATIONS
Winston Steel LLC
Corporate Creations Network Inc.. Agent
15720 John J. Delaney Drive #300
Charlotte, NC 28277
NOTICE OF GROUNDS FOR ADMINISTRATIVE DISSOLUTION OF: Winston Steel LLC
Recently, this office conducted its periodic internal review of annual reports filed in this office for Limited
Liability Companies in North Carolina. Unfortunately, the review indicates that the above referenced limited
liability company is delinquent in filing one (1) annual report(s) and consequently, is not in compliance with
the North Carolina Limited Liability Company Act.
The Secretary of State is authorized by N.C.G.S. 57C-6-03 to administratively dissolve a limited liability
company if grounds for dissolution exist. Failure to file the annual report is grounds for Administrative
Dissolution, This Notice is the first step of the dissolution process. In order to prevent administrative
dissolution, the limited liability company must file the appropriate annual report(s), or show to the
Corporation's Division of the Secretary of State within sixty (60) days from the date of this Notice that each
ground determined does not exist.
Determining Annual Resorts Due .
A list of your annual reports submitted to date is viewable by clicking the link to the Corporations Division
web page at www.sosnc.com. Search for your company by name and then click "File Annual Report Online".
From this page you will be able to see both, if an annual report was submitted but not deemed in "file" status
due to an error that to date has not been corrected and determine how many annual reports are required. The
due date for filing a Limited Liability Company's annual report is April 15. One report is required for each
year beginning the year after the year of creation.
Online Filine
Utilize the above link to the entity's profile page, then click "File an Annual Report" at the top of the page and
follow the directions. The fee is S200.00 plus a $2.00 transaction fee. Please keep in mind that these filing
fees are neither retained nor spent by the Secretary of State's Office, instead they are deposited with the State
Treasurer and are expended by the General Assembly of North Carolina.
Paper Filing
You may also print a pre -populated form at the web address stated above by clicking "Print a Pre -Populated
Annual Report Form". Changes can be made on the Fillable pdf prior to printing the report. Mail the report
and fees to the'address at the bottom of the farm. The fee is $200.00.
If you have any concerns or experience technical difficulty with the filing process, please contact our staffat
[phone] or send an email to [e-mail]
Respectfully,
The Corporations Division
PO BOX �L°�� °a°C°°°'�AHI°-0 IIIIIIIIIIIIII� Illiililll'�Illulll

_ SOSID:0407523
` Date Filcti: 6/71200.18:50:00 AM
CD-479 (ag) Business Corporation use this for nion Elaine F. Marshall
9 19 03 North Carolina Annual Report Annual tReport t file N.C. North Carolina Secretary of State
t t labilrly Partner 2004 159 01 t8
Name of Corporation: WINSTON STEEL COMPANY, INC
Slate at Incorporation: N C Fiscal Year Ending: 1 2— 3 Z— 0 3
+norm / Co, , Yer
Secretary of State Corp, 10 Number: 0407523 Federal Employer 10 Numher:
It this is the initial annual repon tiling, you must complete the entire form. If your business corporation's
information has not changed since the previous report, check the box and complete Line 7 only. 10.
t, Registered agent & registered ollce mailing address: ( Must be a North Carolina Address)
Name:
Street Address:
City, State, Zip Code: County:
2. Mailing address if different from street address:
Mailing Address:
City, Slate, Zip Code:
3. (1 registered agent changed, signature of tier) 39am:
4. Enter principal office address and lelephone number here:
Street Address:
City, Stale, Zip Code:
5. Briefly describe the nature of business:
6. Enter name, title and business address of principal officers here:
Complete Form CO-479A to list additional princ+pal olllCers
Address:
(Signiture consldules conssnt'p the opoomtmenq
telephone:
Name: Title: ---
Address:
Name;
Address:
Title:
7. Certification of annual report (Must be cotpgMtefi(by all corporations).
$i ute lF win mus be d O n oti-I t ) ji-q 'Cx14__
ate
Type or Pr,61 N*kme Tole
309511
10-71.03

S OS I D: 0722399
i'i-.OM W.-It-i'r. & C:A�FE L1,? (MON) 5.:•l, 04 zu -1.5r 1 Dale Filed: 5/18/20043,18:00 PM
Elaine F. Marshall
North Carolina Secretary of State
C200413900599
State of Nurth Carolina
Departtnent of the Secretary of State
ARTICLES OF MERGER
(Cross -entity I%Icrgtr`)
Pursuant to Norm Carolina General Statute Sections 55A I- 10(d). 55A-11-09(d), 57C-9A-23. 59-73.5 and 59-1072.
as applicable, the undersigned surviving cntity does hereby suhmit the follow;ng Articles of Merger as 'fir surviving
business entity in a merger between two or more business entities.
I. The name of the surviving entity is Winston Acquisition LLC , a (check omr) [ ) corporation, [ )
nonprofit corporation, [ ) professional corporation, ( limited liability company, [ I limited partnership. ( ]
partnership, t ):invited liabi:ity partnership organized under the laws of North CaEglina _
2, The dddtesi of the surviving entity is:
Street Address 1947 Union Cross Road tatty Winston-Salem _
State Nnnh Caroline -- Zip Code 27107 CountyFors _ _
'Complete only if the surviving business entity is a foreign husiness entity that is not outhori:ed io iransoct
business or conduct affairs in North Carolina.) The mailing address of the surviving foreign business entity
is:
The surviving foreign business entity will file a statement of any subsequent change in its mailing address %vilh
The North Carolina Secretary of State.
3. The name of the merged entity is Winston Steel Co., Inc. _ a (check one) [corporation. [
) nonprofil corporation, [ ) professional corporation, t ) limited liability company. [ ) limited partnership, [
partnership, [ ) limited liability partnership organized under the laws of North Carolina
J Attached is a copy of the Plan of Merger that was duly approved by each merging business entity or
unincorporated entity to the mariner required by law.
5. With respect to the surviving entity (check the appropriate response):
a. 1 f the surviving entity is a North Carolina corporation or professional corporation:
Shareholder approval was not required for the merger.
(ii)_ Shareholder approval was required for the merger, and the plan of merger was approved by the
shareholders as required by Chapter 55 or Chapter 55B, if applicable, of the Nortli Carolina General
$idi jleb.
If the surviving entity is a North Carolina nonprofit corporation:
(0— Member approval was not required for the merger, and the plan of merger was approved by u
sufficient vote of the board of directors.
(it)_ Member approval was required for the merger, and the plan of merger was approved by the
members as required by Chapter 55A of the ?forth Carolina General Statutes.
t iii)^ Approval of the plan of merger by some person ar persons other than the members or the board was
required pursuant to N C.G.S. Section 55A-11-03(a)(3), and such approval was obtained.
c. If the surviving entity is a North Carolina limited liability company
(i) x Thu merger was approved in the manner provided by the articles of organization or a written
operating agreement providing for approval of a merger with the type of business entity contemplated in
the plan of merger.
(ii)_The merger was approved by the unanimous consent of the members of the limited liability
company.
d. If the surviving entity is a North Carolina partnership, including a limited liability pattnership. or a North
Carolina limucd partnership:

Wd 11 fE; dt CAS3 1_1-P IMUN1 5. 17' t}4 2U::yiF-T 20:15; NU 4db240b521 i' 15•
(t)—The merger was approved in the manner provided in a written partnership agreement that is binding
on all the partners for approval of a merger with the type of business entity contemplated in the plan of
merger.
(ii)_Tbe merger was approved by the unanimous consent of the partners.
C. The surviving entity is a foreign entity, including a corporation, nonprofit corporation, professional
corporation, limited liability conparry, partnership, limited liability partnership or limited pannership, and
the merger was approved in accordance with the laws of the state or country governing the organization and
internal affairs of the foreign entity.
J. With respect to the merged entity (check the appropriate response):
a. If the merged entity is a North Carolina corporation or professional corporation:
(I)_ Shareholder approval was not required for the merger.
(ii) x Shareholder approval was required for the merger, and the plan of merger was approved by the
shareholders as required by Chapter 55 of Chapicr SSB, if applicable, of the North Carolina Gcncral
statutes.
b. If the merged entity is a North Carolina nonprofit corporation:
(i) Member approval was not required for the merger, and the plan of mcrger was approved by a
sufflc tent vote of the board of directors.
(ii)_ Member approval was required for the merger, and the plan of merger was approved by the
members as required by Chapter 55A of the North Carolina General Statutes.
(ui)_ Approval of the plan of merger by some person or persons other than the members or the board was
required pursuant to N.C.G.S Section 55A -1 1-43(a)(3). and such approval was obtained.
c. if the merged entity is a North Carolina limited liability company:
(i)._The merger was approved in the manner provided by the articles of organization or a written
operating agreement providing for approval of merger with the type of business entity contemplated rt1
the plan of merger.
Oil —The merger was approved by the unanimous consent of the members of the limited liabtiity
company.
If the merged entity is a North Carolina partnership, including a limited liability partnership, or a North
Carolina limited partnership:
(i)_The merger was approved in the manner provided in a written partnership agreement that is binding
on all the partners for approval of a merger with the type of business entity contemplated in the plan of
merger: or
(it)^The mcrger was approved by the unanimous consent of the partners.
(: ii)_lf any partner of the domesric pairtact-ship or domestic limited partnership has or will have personal
habdily for any existing or future obligation of the surivivng business entity solely as a result of holding an
interest in the surviving business entity, then in addition to (i) or (ii), above, the plan of merger was
approved by that partner.
e, Ttic merged entity is a foreign entity, including a corporation, nonprofit corporation, professional
corporation, limited liability company, partnership, limited liability partnership or limited partnership, and
the merger was approved in accordance with the laws of the state or country governing the organization and
internal affairs of the foreign entity.
7. The merger is permitted by the law of the state or ccusltry governing the organization and internal affairs of
each merging business entity.
S. Each business entity that is a party to the merger has complied or shall comply with the applicable laws of the
state or country governing its organization and internal affairs
7. These articles will be effective upon filing, unless a delayed date andlut tints is specifiud:

• 'r.1014 igSi FE &. CASE Li P (MON) 5 1 7' 04 90: 1 8,'ST. 20: 1 5/N0, 4962406521 F 16
'this the {l day of 2004
Winston A;quisjien, L
v 11,
Kurt J. Langsenkamp, Vice President �tn,cgEY-
Type o+' Print Name and Tirle II
N01'F.s:
'A 'Cross-cniiiy Merger" may involve one or more bwinm corporations, nanprofit corporations, lirnited liability companies. p:vinershups.
lirnaed liability partnerships or limited partnerships. The phrase "Cross-e„ tiry ?,Acrger" is used solely Cur adrnwwnrn a and rdenhficanrnl
purpows s%-,Uun the Depanment ofthe Secretary of State.
I. Filing fee is 550. This document must be filed with the Smrctiry of Sft
2. Certificate(s) of Merger must be registered pursuantto the regairemenh of N.C.G.S. Section 47-18.1
CORPORATIONS DIVISION P. 0. BOX 29622 RALEIGH, NC 27625-0622
(Rr1,,3edJurruu;-Y2002) (Fa)-m HE•!ji

�4:Jti5 WH.: ! K & LASE LLF WON) 5. : Y' V4 20 . : t3/5'1' 20: 1 5,W) 4136:M0652? P ) T
PLAN OF MERGER
OF
WINSTON STEEL CO_, INC.
AND
WINSTON ACQUISITION LLC
This Plan of Merger dated as of May 17, 2004, is made by and between
FABTECH INDUSTRIES, INC., a corporation organized and existing under the laws of the State
of Delaware ("FABTECH" or the "Seller"), WINSTON STEEL CO., INC., a corporation
organized and existing under the laws of the State of North Carolina ("W tNSTON" ), and
WINSTON ACQUISITION LLC, a limited liability company organized and existing under the
laws of the State of North Carolina ("ACQUISITION" or the "Surviving Company").
RECITALS
WHEREAS, the Board of Directors of FABTECH has approved the acquisition of
WINSTON, a wholly -owned subsidiary, by ACQUISITION in exchange for cash and other
consideration; and
WHEREAS, in accordance with the terms of the Purchase and Sale Agreement by
and between FABTECH, WINSTON, other affiliates of WINSTON and FABSOUTH LLC, a
Delaware limited liability company, and pursuant to this Plan of Merger, WINSTON shall be
merged with and into ACQUISITION (the "Merger") and, incident to the Merger, all the issued
and outstanding shares of the common stock of WINSTON shall be cancelled. Each of the
parties hereto wishes to set forth in this Plan of Merger the terms and conditions of the Merger,
the niode of carrying the Merger into effect, the manner and basis of transferring all assets and
properties of every description and wherever located of WINSTON and its rights, privileges,
immunities, powers, franchises and authority, public as well as private, and such other terms and
conditions as may be required or desired and permitted. The Board of Directors of WWSTON
and the Board of Managers of ACQUISITION deem the Merger desirable and in the best
interests of its shareholder or members, as the case may be, and each Director has, by unanimous
consent in writing, adopted and approved this Plan of Merger, and directed that this Plan of
Merger be submitted to its respective shareholders for their approval.
AGREEMENT
In consideration of the mutual covenants set forth in this Plan of Merger, the
parties agree as follows:
l . On the Effective Date (as defined in paragraph 6 below), in accordance
with the provisions of this Plan of Merger and the provisions of the North Carolina Business
Corporation Act and Limited Liability Company Act, WINSTON shall be merged with and into
ACQUISITION, which shall be the Surviving Company, and the separate existence of
LUAM A5600.1 OKI

F'.,OM 44HI VE G. CASE LLP (MUN) S. 17' 04 70.:81ST 10=)SIN0. 4t367406571 Y 18
WINSTON shall cease. ACQUISITION, as the Surviving Company, shall possess and retain
every interest in all assets and properties of every description and wherever located of
WINSTON. The rights, privilcges, immunitics, powers, franchiscs and authority, public as well
as private, of WINSTON shall be vested in the Surviving Company without further act. All
obligations due to WINSTON shall be vested in the Surviving Company without further act. The
Surviving Company shall be liable for all of the obligations of WINSTON existing as of the
Effective Date,
2. The Articles of Organization of ACQUISITION as in effect on the
Effective Date shall remain in effect and be the Articles of Organization of the Surviving
Company except that Article 1 thereof, relating to the name of the limited liability company, is
hercby amended and changed so as to read as follows upon the Effective Date:
The name of the Limited Liability Company is Winston Steel LLC,
3. The Limited Liability Company Agreement of ACQUISITION as in effect
on the Effective Date shall remain in effect and be the Limited Liability Company Agreement of
the Surviving Company.
4. The Board of Managers and officers of ACQUISITION at the Effective
Date shall be the Board of Managers and officers, respectively, of the Surviving Company, until
their successors shall have been elected or appointed, as the case maybe, and, duly qualified.
5. On the Effective Date, by virtue of the Merger and without any further act,
the issued and outstanding shares of the common stock of WINSTON shall be cancelled.
6. The Merger shall become effective on the day that the Articles of Merger
for the Merger have been filed with the Secretary of State of North Carolina (the "Effective
Date").
7. The proper officers of the Constituent Corporation and of the Surviving
Company, respectively, are duly authorized, empowered, and directed to do any and all acts and
things, and to make, execute, dcliver, file, and/or record any and all insmLmcnts, papers, and
documents which shall be or become necessary, proper, or convenient to carry out or put into
effect any of the provisions of this Plan of Merger or of the Merger.
-2-
MLA.W 469010 4 (M)

FROM WHITE & CASE -'-P (M3.141 5 i l' 04 7tt : 1 S/ST. 70: 1 5/NO. 436740652 1 F 14
IN WITNESS WHEREOF, WINSTON and ACQUISITION have caused this Plan
of Merger to be signed in their corporate names by their respective authorized officers as of the
day and ycar first above written.
WINSTON STEEL CO., INC., a North C
corporation
LA
Title: -�k C'-. YktSldC-4,1
WLNSTON ACQUISITION}LLC' a North
Carolina limited liabilityj4parA-
Title:
-3

�* AF�"F�
LIMITED LIABILITY COMPANY
�4 1,Y ANNUAL REPORT
NAME OF LIMITED LIABILITY COMPANY: T insion Steel LLC
SECRETARY OF STATE L.L.C. ID NUMBER: 0722399
NATURE OF BUSINESS. Miscellaneous:lfetals Fabricator
REGISTEREED AGENT: Cotpot•crte Creations A'ettivork Inc.
1-Filecl Annual Report
-1-0-64613 40
For year 2010
Do not data enter manually.
STATE OF INCORPORATION: NC
REGISTERED OFFICE MAILING ADI)RESS: L5720 John) Delanev Drive #300
Charlotte, XC 28277
REGISTERED OFFICE STRI-E'l- ADI)RIESS- 15720JohnJ. Delanev Drive ii300
Charlotte, Ar(. 28277,11ecklenburgCounh,
PRINCIPAL OFFICES TIELEPE-IONIE NUMBER: 3367886151
PRINCIPAL OFFICE MAILING ADDRI"sSS: 1947 Union Cross Road
IVinston Salem, rVC 27107
PRINCIPAL OF ICE STREET ADDRESS' 1947 Union Cross Road
IVinston Salem, ArC 27107
MANAGERS11v9E;A13ERSIORGANI7ERS-
Arcmre: Steve Darnell Almne: David A -(organ
Title: A-lember Title: Member
Address: Address:
1947 Union Cross Road 1947 Union Cross Road
Winston Salem, ArC 27107 Il"insion Salem, NC 27107
Almne: Penny Hege Name: Tom Tucker
Title: Member Title: ,1lenrber
Address: Address:
1947 Union Cross Road 1947 Union Cross Rowl
II.7nsion Salem, A'C 27107 II'insion Salem, ATC 27107
Nernre: Smnnry Larrghn
Title: Afember
Address:
1947 Union Cross Road
fVinsion Salem, :VC 27107
Name: Toni Craver Jr
Title: ,11enrber
Address:
1947 Union Cross Road
Ii inston Salem, ,VC 27107
Almne: Kurt Langsenkwnp
Title: Afernber
Address:
1947 Union Cross Road
FI.7nston Salem, A'C 27107
CERTIFICATION OF ANNUAL R-SPORT MUST BE COMPLETED BY ALL LIMITED LIABILITY COMPANIES
Steve Darnell
FORM MUST 13E SIGNFD RYA MANAGER/MEMBER
Steve Daniel]
03/11/2010
DATE
Membcr
TYPE OR PRINT NAME TYPE OR PRINT TITLE
. NNUAL REPORT F EE: $200 MIL TO: Secretary of State - Corporations Division • Post Office Box 29525 • Raleigh, NC 27626-0525

MANAGERS/MEMBERS/ORGANIZERS: (Continued)
Name: Sammy Vaughn
Title: Member
Address:
1947 Union Cross Road
Winston Salem, NC 27107

Permit; NCGO30528
SOC:
County: Forsyth
Region: Winston-Salem
Contact Person:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 04/30/04 Expiration: 08/31107 Owner: Winston Steel & Stair
Effective: Expiration: Facility: Winston Steel & Stair
219 Junia Ave
Inspection Date: 08/07/2008
Primary Inspector: Rose Pruitt
Secondary Inspector(s):
Title:
Entry Time: 09:00 AM
Certification:
Winston Salem NC 27106
Phone:
Phone:
Exit Time: 11:00 AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: 0 Compliant ® Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

'Permit: NCG030528 Owner - Facility: Winston Steel & Stair
Inspection Dale: 08/07/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted by Don Donadio with WS SW Division
Page: 2

August 26, 2008
Ms. Christine McClaren
Assistant Safety Director
Winston Steel and Stair
216 Junia Avenue
Winston-Salem, N.C. 27127
Dear Ms. McClaren:
RECEIVED
N.C. Deot. of E,Vq
AUG 2 7 2008
4�lir,s!on-Salam,
Regional Office
Public Works Department
Stormwater Division
Ciryof Winston-Salem
P.O. Box 2511
Winston-Salem, NC 27102
Tel [phone]
Fax [phone]
w .ciryofws.org
The Stormwater Division of the City of Winston-Salem would like to thank you for your time and
professional courtesy regarding the August 7, 2007 inspection of the Winston Steel and Stair Plant.
As per your request, a photocopy of the completed inspection form has been enclosed to you.
The Stormwater Division is requesting notification upon completion of annotations 9 1 — 7 that are
denoted in Part 4, Required Actions to be completed by the Facility, which is located on your
surface water inspection form. Upon notification, an informal inspection will be scheduled for
verification purposes.
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 [phone].
Sincerely,
Donald P. Donadio
Stormwater Industrial Inspector
City of Winston-Salem
Cc: Rose Pruitt, Environmental Specialist with the North Carolina Division of Water Quality

City of Winston-Salem
Stormwater Division
Surface Water inspection for Industrial Sites
Part 1 - General Information
A) Official Company Name: Winston Steel and Stair Inc.
B) 1. Physical Address: 216 Junia Avenue Winston-Salem, NC 27127
2. Telephone Number: 336-721-0020
C) Mailing Address, if different from above address:
D) 1. Primary contact who is authorized to represent company in official business:
Mike Carcieri
Title: Vice President of Operations Contact number: [phone] ext. 207
2. Secondary contact: Christine McClaren
Title: Assistant Safety Director Contact number: [phone]
E) SIC Code Number of business: 3323
F) NC Stormwater NPDES Permit Number:
Facility Type Metal fabricator
NCG030528
G) Any other control authority permit(s) (ex.: air control, wastewater, hazardous waste) & number(s):
no
H) Brief description of manufacturing process of products produced on site:
Construction of steel stairs, balconies, and railings.
Raw steel is cut, welded, assembled, and painted into a finished product.
1) Receiving Water(s)IMS4: Salem Creek
Part 1 - Stormwater Controls
1. Best Management Practices
a. List the non/structural controls employed by the facility
1. Secondarycontainment at kerosene and diesel area is enclosed and has sufficient capacity.
2. Good house keeping practices -facility was free of debris and litter.

b. Are the BMPs reasonable & appropriate for the facility yes x no
Comments: - Facility needs to cover metal scrap bin, insert plug in drain of dumpster, and provide
' adequate volume of secondary containment structure for stored barrels.
c. Are BMPs installed correctly, maintained, and in effective operating condition? yes x no
Comments: Numerous BMPs have not been installed at the facility.
2. Provide a brief description of other controls that manage/prevent/minimize stormwater runoff
(e.g., erosion and sediment controls, inlet protection/control at storm drains, diversion structures):
The kerosene and diesel storage area is covered, secured, and has adequate containment.
Part 2 - Miscellaneous
1. Any evidence of discharge to receiving waters/MS4? (e.g.: stormwater runoff, dry weather
discharge, co -mingling of process wastewater): x Yes No
Comments: 1 Stormwater runoff to MS4
2) Dry weather flow is from Sunnyside Ice Company.
2) Do the stormwater outfalls on -site correspond with those listed on the site map and in SPPP?
Yes x No N/A
Comments: Stormwater discharge outfalls need to be denoted on site map and SPPP. In addition, use
arrow symbols to indicate the direction of sheet flow on the site map. _
Part 3 - SPPP Review (can be completed in office)
General NOTES
1 Is there a SPPP?
Yes
No
2) Does SPPP identify a specific position(s) for
responsible party purposes (e.g.: overall coordination,
Yes
No
development, implementation, & revision
3) Does SPPP designate facility personnel
Yes
No
responsible for implementing SPR?
4 Does SPPP include a certification statement?
Yes
No
5) Are employee training records regarding stormwater
pollution prevention topics included in SPPP?
Yes
No
*Comments*:
1) An USGS quadrangle (or equivalent) map was not incorporated into SPPP. In addition, Salem Creek was not
listed as the receiving stream. _
2) Narrative of potential pollutants to stormwater discharge outfalls is not present.
3) Incorporate a list of previous_significant spills into your SPPP. If no significant spills have occurred, include a
certified statement affirming this fact.
4) Site map is inadequate due to no designations of catch basins, SDOs, or sheet flow direction_ .
5 Revise the SWPPP to reflect changes and submit to Stormwater Division.

Site Map
NOTES
1 Is there a site map?
Yes
No
2 Drainage atternsloutfalls
Yes
No
No direction of sheet flow
3) Identification of potential pollutants likely
to be discharged from each drainage area?
Yes
No
4) Narrative Description and locations of (check if present):
1. Storage Practices
2. Unloading/Loading activities
3. Outdoor processes
4. Particulate generating/control processes
5. Waste Disposal
No narratives present
5 Name of receivin waters or MS4's listed?
Yes
No
6) Locations of significant materials exposed
to stormwater?
Yes
No
7) Locations and descriptions of major spills occurring within the
the 3 pervious years (wl corrective actions to prevent future spills)?
Yes
No
Stormwater Controls
NOTES
1) Does the SPPP describe the non-structural
controls that will be used to prevent/reduce
Yes
No
discharge of pollutants in stormwater runoff?
2) Does the SPPP describe the structural
controls that will be used to prevent/reduce
Yes
No
discharge of pollutants in stormwater runoff?
3) Does the SPPP describe other controls that
will be used to prevent/reduce off -site tracking
or blowing of sediment, dust, and raw, final,
Yes
No
or waste products, or other solid materials
and floating debris?
4) Does the SPPP incorporate the 8 baseline
controls (good housekeeping, BMP summary,
feasibility study, PM, SPR procedures, facility
Yes
No
inspections, and comprehensive site evaluations,
employee training, secondary containment, and
sediment control?
5) Does SPPP contain completed routine inspection
reports/logs regarding reportable implementation
Yes
No
of the 8 baseline controls?
6) Does the SPPP describe the pollutant or activity
to be controlled by BMP's and assessed the need
Yes
No
of implementation through data collected?
Nan-stormwater Discharges
NOTES
1) Certification that the facility has been tested
Yes
No
for non-stormwater discharges from the site?
2) Description of testing method, drainage
Yes
No
points, observed results, date, and signature?

Monitoring
NOTES
1) Are samples collected within 30 minutes of
measurable weather events occurring 72 hours
Yes
No
after previous measurable weather event?
2) Were samples collected and preserved in
Yes
No
accordance with 40 C!✓R 136?
3) Was proper chain -of -custody procedures
Yes
No
followed?
4) Was analytical and qualitative monitoring
Yes
No
complete?
Any exceedences of pollutant parameters in regards
Yes
No
Denote SDOs on site map
to cutoff concentrations/effluent limits?
and specify sampling sites.
Part 4 - Required Actions to be completed by Facility:
1. SPPP is too qeneral and needs to address specific, implemented BMPs.
2. Site map needs to display the percentage of impervious surface within each drainage area, stormwater discharge outfalls,
and all designated sampling sites.
3. Incorporate a narrrative description of industrial activities that occur on -site as well as possible pollutants which could be
present in stormwater runoff from each outfall. Please refer to Part II, Section A(1.)(b)_of your permit.
4. Certify that stormwater outfalls have been evaluated for the presence of non-stormwater discharges. Please refer to
Part 11, Section A(1_)(e) of your permit.
5. Paint and paint thinner shall be stored under cover, and provide sufficient secondary containment capacity._
6. Dumpster must have a drain plug installed - contact your contracted garbage disposal company re arg ding this matter.
7. Scrap steel in large recycling bin shall be covered to prevent rainwater from making direct contact.
8. Please complete Compliance Measures #1 - #5 by November 25, 2008 and keep the Stormwater Division abreast of Your
progress to comply with these permit requirements. Upon completion of major milestones, please provide written notification
to the Stormwater Industrial Inspector. _
9. Please complete Compliance Measures #6 - #7 within 15 days upon receipt on this _in_spection form. Upon completion,
please notify the Stormwater Industrial Inspector and a reinspection will be scheduled.
10. * = Incorporate the absent permit requirements into your SPPP refer to the Comments in Part 3). Submit your ^'
revised SPPP to the Stormwater Industrial Inspector upon completion.
Educational resources:
1. NC Stormwater Manual for Industrial Users:
http://h2o. enr, state, nc. us/su/PDF Files✓SW Documents/SWPPP GD. PDF
Company representative(s) that participated in inspection: Chrisitine McClaren and Dave Collins
Title: Assistant Safety Director and Plant Manager
Start of Inspection
9:00 AM
Completion of Inspection: 11:00 AM
Date: 8/7/2008
Signature of City Stormwater Inspector: /6: is L
Title: Stormwater Industrial Inspector

WWI
Alk
Scrap metal container must be covered.
Barrels stored on secondary containment that is inadequate for volume stored

Naptha is stored outside and has no spill containment

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, Director
Mr, Steve Darnell
Winston Steel & Stair
219 Junia Avenue
Winston-Salem, North Carolina 27106
Dear Mr. Darnell:
NCDEN11
NORTH CAROUNA DF-'ARTMENT OF
ENVIRONMENT ANo NATURAL RESOURCES
April 30, 2004
Subject: General Permit No. NCG030000
Winston Steel & Stair
COC NCG030528
Forsyth County
In accordance with your application for discharge permit received on March 24, 2004, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES
general permit. This permit is issued pursuant to the requirements of North Carolina General Statute
143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental
Protection agency dated May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies, or sampting requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual
permit application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the
Division of Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality or pert -nits required by the Division of Land Resources, Coastal Area
Management Act, or any ether Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Ken Pickle at telephone number
[phone] ext. 548.
ORIGII ktfila�ED BY
WILLIAM G. MILLS
1�Ylan W_ Klimek, P. E.
cc: Winston-Salem Regional Office
Central Files
Stormwater and General Permits Unit Files
SWU-759•0I IrV
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030528
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Winston Steel & Stall,
is hereby authorized to discharge stormwater from a facility located at
Winston Steel & Stair
219 Junia Avenue
Winston-Salem, North Carolina
Forsyth County
to receiving waters designated as Winston-Salem municipal separate storm sewer system to unnamed tributary to
Salem Creek, a class C water in the Yadkin River Basin
in accordance with the eft1uent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III,
IV, V, and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective April 30, 2004.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 30, 2004.
ORIGINAL SIGNED BY
--1---X"1aV&UAW& r
Division of Water Quality
By Authority of the Environmental Management Commission

Copyright (C) 1997, Maplech, Inc-