NCG080023_Inspection Report (City of WS)_20210408

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Winsoo SWem
December 31, 2020
pield Operfllians
Slonnwater Division John Ashford
Assistant General Manager
CityorWinston-salem Winston-Salem Transit Authority
Po. Box 2511 P.O. Box 2511
Winston-Salem, NC27102 Winston-Salem,. NC27102
CityLink336.727.8000
Dear Mr. Ashford:
The Stormwater Division of the City of Winston-Salem would like to thank you for
your time and professional courtesy regarding the December 18, 2020 inspection of
Winston-Salem Transit Authority's Maintenance Facility.
A copy of the completed inspection form has been enclosed to you. Part 5 of this
report (Required Actions to be completed by Facility) contains Annotations #1-15 that
WSTA must complete. Please provide documentation that verifies WSTA
successfully completed the corrective measures to me by April 5, 2021,
The Stormwater Division reserves the right to enter Winston-Salem Transit
Authority's Maintenance Facility as often as necessary to determine compliance with
the permit requirement of NCG080023.
Thank you for your continued support of the City of Winston-Salem's Stormwater
Program. If you have any questions, please feel free to contact me.
Sincerely,
Brandon ise, CESSWI
Stormwater Inspector
Office: [phone]
Cell: [phone]
E-Mail: [e-mail]
City CouncB: Mayor Allen Jeines; Denise D. Adams, Mayor Pro Tempore, North Ward; Dan Besse, Soudnvest Ward; Rohert C. Clark,
West Ward; Jahn C. Larson, Soulh Ward; Leff Macintosh, Northwest Ward; Morticia "Tee -Tee" Pannoq Northeast Ward; Annette Scippiq
Call 311 or 336-727-8000 East Ward; James Taylor, Jr., Southeast Ward; City Manager. Lee D. Garrity
[e-mail]

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Stormwater/Erosion Control Division
Industrial and Municipal Good Housekeeping Inspection Form
General Information
A) Official Company Name: Winston-Salem Transit Authority
B) Physical Address: 1060 Trade Street NW, Winston-Salem, NC 27101
C) Telephone Number: 33G-727-2006(0)
D) Mailing Address, if different from above address: PO Box 2511, Winston-Salem, NC 27102
E) Authorized contacts to represent entity in environmental regulatory issues:
Primary contact: Donna Woodson
Title: General Manager
Contact number(s): 3364274006(o)
Email address: [e-mail]
Secondary contact: John Ashford
Title: Assistant General Manager/Maintenance Manager
Contact number(s): 336427-2006(o)
Email address: [e-mail]
F) Standard Industrial Classification (SIC) Number of business/operafion (if applicable): 4111
Local and Suburban Transit
G) NC Stormwater NPDES Permit Number (if applicable): NCG080023
Permit Category: Transit and Transportation
ITJ Any other control authority permits) (e.g. air quality control, wastewater, hazardous waste) & number(s):
NCD981859424 - RCRA
I) Brief description of facility activities that occur on -site:
%7 is used as for performing of maintenance on city buses and bus parts. Facility also houses
bus parking and a large wash bay for washing of vehicles.
I) Ultimate
Receiving Waters:
Peters
Creek
TMDL
stream
❑Yes
®No
If Yes, What Pollutants:
Part 1- Stormwater Controls
l . Best Management Practices (BMPs)
a. List the controls (structural or non-structural) employed by the facility:
E.g. Oil Water separators, cleaning schedules, structural BMP maintenance records
1. Oil -water separator used for all drains inside of maintenance and washing facility.
2. Monthly facility inspections
3. Oil absorbent kept at catch basins near fueling areas, replaced as needed.

b. Are the non-structural BMPs reasonable & appropriate for the facility? ❑Yes ®No
A more rigorous inspection and cleaning schedule should be implemented for the bus
parking area of the facility. While the rest of the facility appeared clean and maintained,
there was evidence of consistent oil leaks at the bus parking area of the facility.
c. Are stormwater control measures (SCMs) installed correctly, maintained, and effective operating condition?
❑Yes ❑ No ® N/A
No SCMs 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):
Oil absorbent pillows are kept at the catch basins that could be subject to fuel spills.
Part 2 —Stormwater Discharge Outfalls (SDOs)
1. Any evidence of discharge to receiving waters/M54 from the SDOs? (e.g.: stormwater runoff, dry weather
discharge, co -mingling of process wastewater, trash, debris, oil and grease): ❑Yes ®No
No evidence of discharges to the MS4 were noted in any of the stormwater conveyances
observed at the facility.
2) Do the stormwater outfalls on -site correspond with those listed on the site map in the Stormwater Pollution
Prevention Plan(SWPPP)? ®Yes ❑No
Single outfall located at a curb inlet near the gasoline fueling station.

3) Summary of Stormwater Discharge Outfalls
SDO Identification
Potential Pollutants that
Physical Location
Latitude and
could be discharged
Longitude
if known
Outfall #1
TSS, Oil & Grease, Wash
Curb inlet to the south of
36.107163,-80.248022
water, Antifreeze
gasoline fuel pump

Part 3 - BMP: Inspection and maintenance program
Yes N/A No Notes
Is secondary containment provided for materials (including
X
Underground tanks along
waste) or products stored outside in tanks and/or containers
with built-in secondary
where applicable)?
containment.
Are secondary contaimnent free of accumulated water, debris,
X
cracks, holes, or evidence of leaks?
Does the facility maintain secondary containment drain logs?
X
No containment needs
pumping*
Do the drain logs confirm the presence of pollutants and other
X
See above.
pertinent information, such as signatory requirements, name of
secondary containment area, date, time, and if drainage is
connected to MS4 or receiving waters?
Are tanks and containers in good condition, closed, and
X
New oil tank in
properly marked?
maintenance facility
needs new NFPA label.
Used oil filter container
needs to be labeled.
Are tanks, containers, and piping free of rust, pits,
X
deterioration, or evidence of leaks?
Are tanks and containers protected from impacts from moving
X
Underground or indoors.
vehicles and equipment? E.g. bollards and curbs
Any activities that have not been addressed or designed in
X
order to minimize exposure to runoff (e.g. herbicide
application)
In the case of a spill, does the municipal operation or industrial
X
Keith Huffs information
facility maintain and submit documentation to the City of WS
in spill response.
on a spill release form?
Any roof stacks that have the potential to release
X
solids/particulate?
Are all hazardous materials properly labeled and stored to
X
New oil tank in facility
prevent exposure to stormwater runoff9
needs new NFPA label.
Are solid waste containers in good condition and of sufficient
X
Removed as needed.
size to contain all waste? If so, how is this determined?
Do the solid waste containers have covers and closed drain
X
Drain plug missing from
lugs?
waste container.
Are solid waste containers free of waste that requires special
X
Solid waste container
handling/disposal? Are containers properly labeled to ensure
need to be labeled
correct disposal means?
properly.
Are solid waste containers labeled "Prohibited = No Hazardous
X
Solid waste container
Waste, No Recyclable Materials, No Liquids?"
needs to be labeled.
Are special containers provided for other types of waste? E.g.
X
One large roll -off
liquid waste or hazardous waste
container for used parts
under cover.
Does the facility utilize oil water separators? If yes, are the
X
Cleaned out as needed.
inspection and maintenance records documented?
Are secondary containment drain valves maintained in the
X
All drains had locks on
closed position, unless the facility is draining the secondary
lock out valves.
containment?

Part 4 — Stormwater Pollution Prevention Plan (SWPP) Review
Site Overview
Yes No Notes
Is there a SWPPP? Is it up-to-date?
X
Last updated in 2015.
Does SWPPP include a certification statement by the responsible
X
Last updated in 2015.
corporate officer?
Does the general map depict the facility's location on a USGS
X
Needs waters designated on
quad map (or equivalent map) with receiving waters (or MS4)
quad map.
listed?
Identification of impaired waters or watershed (if applicable)?
X
N/A
Narrative Description of these Industrial/Operational Activities:
Narrative descriptions are
Storage Practices
X
scattered through the 2015
Unloading/Loading Activities
X
SWPPP. There is no
Outdoor Processes
X
description for the
Particulate Generating/Control Processes
X
unloading and loading of
Waste Disposal
X
products such as the
Vehicle/Equipment Washing
X
antifreeze, new oil,
transmission fluid. Some
details were given in the
2017 SPCC but need to be
placed in the SWPPP as
well.
Does site map denote drainage items: flow direction, boundaries,
X
Site map at the facility had
% impervious, and structures? Does the map also include SDOs,
all requirements.
industrial activity areas, and site topography?
A list of major spills that have occurred within the past three years
X
Kept in stormwater book in
with corrective actions to prevent futurespills)?
office.
A signed, annual certification that the facility has been tested for
X
Dry weather monitoring
non-stormwater discharges from the site?
must be completed
annually with certification
of non-stormwater
discharges.
Comments:
SWPPP is out of date and needs to be updated. The SPCC provided (dated
2017) has some details that would cover requirements for the SWPPP and
can be translated to the updated SWPPP. The narrative description section
of the SWPPP should be brought together in a more cohesive manor in order
to properly disclose all activities performed at the facility. Annual
certifications for the SWPPP and non-stormwater discharges should be
completed on an annual basis. In order to certify non-stormwater discharges
dry weather monitoring must be completed on an annual basis at the
minimum.

Stormwater Management Strategy
Yes No Notes
Does SWPPP incorporate the nine baseline controls:
X
X
Needs to be done.
Feasibility Study (technical & economic review to minimize pollutant exposure)
Secondary Containment (table summary of tanks, stored materials, release records)
X
In SPCC.
X
BMP Summary (listing of site structural/nonstructural practices)
PM & GH (inspection of material handling areas & regular cleaning schedules)
X
Part of monthly inspections
Facility Inspections (biannual inspections of facility and all stmanwater systems,
X
Inspections done monthly
were the inspections completed during separate parts of the year?)
X
Training should be completed
Employee Training (annual basis for staff who perform SPRP and GH functions)
annually along with a log
showing who attended.
Responsible Party (specific position(s)/person(s)-developing, implementing, &
X
Needs to be updated along
revising SWPPP)
with other certifications.
X
Certifications need to be doneannually .
Amendment & Annual Update (of major spills, non-sw flows, BMPs, sampling data)
Does SWPPP contain completed routine inspection reports/records
X
regarding reportable implementation of the nine baseline controls
(e.g. SWPPP Implementation)?
Does the Spill Response Procedures (SPRP) document all spills and
X
Spill response procedures are
releases? Does the entity properly dispose of contaminated materials
covered in the SPCC along
used in the clean up? Is the disposal of materials documented? Has a
contact person(s) and contact information been identified and
documented for each facility?
with who is responsible and
how to dispose/report the
spill'

Analytical Monitoring (f not applicable, please notate)
Yes No Notes
Are samples collected within 30 minutes of the first discharge from
X
a measurable rain event and at least 72 hours since the last storm
event?
Are sampling lin events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
X
Is analytical monitoring complete (including schedule) for each
X
Single outfall at the facility.
SDO? (EXCEPTION: REPRESENTATIVE OUTFALL S•PATUS)
Any exceedances of pollutant parameters when compared against
X
No exceedances in current
the permit benchmark values? If yes, have they documented their
permit period. Last
response to the Department of Environmental Quality?
exceedance documented
was in 2016.
X
N/A no exceedances in
Has the facility implemented appropriate, selected actions to
current permit term.
reduce pollutant concentrations, in response to benchmark
Facility is currently in
exceedances (if applicable)?
"Tier 0" status.
Qualitative Monitoring
Yes No Notes
Is qualitative monitoring being performed during measurable storm
X
events?
Is qualitative monitoring complete (including schedule) for each
X
SDO?
Are monitoring events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
X
X
Some discoloration. No
Any observable, excessive amounts of pollutant indicators in
signs of pollutants from
stormwater discharge at SDOs?
facility.

Part 5 — Required Actions to be completed by Facility:
Items to be completed within 3 months of receipt of this report:
1) Properly label oil dry container located at the main fueling area. During the inspection the
container was open and being used for garbage (See Photo 1)
2) Place a new correct NFPA label on the new oil tank located inside of the facility. (See Photo 2)
3) Properly label the used oil filter waste container to document what is allowed to be thrown away
in the container. (See Photo 3)
4) The waste container at the facility needs a plug to prevent waste "juice" from reaching the
stormwater. (See Photo 4)
5) Properly label the waste container at the facility to ensure no industrial waste is being discarded
in the container. (See Photo 5)
6) Ensure oil leaks in the bus parking area are cleaned up on a consistent basis to prevent the oil from
reaching the storm drains. Oil spot in photo should be cleaned up immediately. The oil spots that are
observed to be still wet should be cleaned up immediately. (See Photo 6)
7) A copy of the facility's most recently updated SWPPP must be available at the facility at all
times. Ensure a copy of the SWPPP is added to the stormwater documentation at the facility.
8) The information in the 2015 SWPPP needs to be inspected and it must be accurate to the current
site operations and conditions.
9) Facility's SWPPP needs to have the quad map updated to show the receiving stream.
10) Facility needs to have the narrative description of all practices at the facility properly placed in
the SWPPP and must add information about the loading and unloading processes.
11) A feasibility study along with a summary of BMPs at the facility must be added to the SWPPP
per the requirements of the permit.
12) Employee training at the facility must be documented and kept with the certifications and
sampling records for the required five years.
13) Dry weather monitoring is a requirement of the NCG08 permit and must be completed in order
to certify the facility for non-stormwater discharges.
14) Non-Stormwater certification, annual SWPPP certification, and a major spill certifications must
be completed annually. Once completed these certifications must be kept on site with all certified
sampling data.
15) Due to evidence of discoloration in qualitative monitoring and oil staining, the facility needs to
increase good housekeeping inspections and cleaning frequencies to ensure pollutants do not reach
the MS4's stormwater system.

Entity Representative(s) that participated in inspection: John Ashford
Title(s): Assistant General Manager
Start of Inspection: 9:20
Completion of Inspection: 10:45
Date: 12/18/2020
Signature of Inspector:
Title: Stormwater Inspector

Photo 1—Oil dry container located at the main fueling area, currently uncovered and being
used for trash.
Properly label oil dry container located at the main fueling area. During the inspection the
container was open and being used for garbage

Photo 2 —New oil tank located inside of the facility with old NFPA label
Place a new correct NFPA label on the new oi] tank located inside of the
facility.

Photo 3 —Used oil filter waste container
Properly label the used oil filter waste container to document what is allowed to be thrown
away in the container.

Photo 4 —Waste container at the facility missing a drain plug
The waste container at the facility needs a plug to prevent waste `juice" from reaching the
MS4's stormwater system.

Photo 5 —Waste container located at the facility
Properly label the waste container at the facility to ensure no industrial waste is being
discarded in the container.

Ensure oil leaks in the bus parking area are cleaned up on a consistent basis to prevent the
oil from reaching he storm drains. Oil spot in photo should bcc caue up immediately.
The oil spots that are observed to be still wet should be cleaned up immediately.