NCG130008_Inspection Report (City of WS)_20210408

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WHS10118swem
Field Operations
Stomimler Division
Croy of Wimmn-Salem
110. Box 2511
Winston-Salem, NC 27102
CityLink 336.727.9000
February 12, 2021
Derek Bouchard
Environmental Manager
Republic Services
1070 Riverside Drive
Asheville, NC 28804
The Stormwater Division of the City of Winston-Salem would like to thank you for
your time and professional courtesy regarding the January 15, 2021 inspection of
Republic Services — Lowery Street Recycling Facility.
As per our discussion, a copy of the completed inspection form has been enclosed to
you. Part 5 of this report (Required Actions to be completed by Facility) contains
Annotations #14 that Republic Services must complete. Please provide
documentation that verifies Republic Services successfully completed the corrective
measures to me by May 14, 2021. Please ensure a copy of this report is kept at the
facility for records as well.
The Stormwater Division reserves the right to enter Republic Services —Lowery
Street Recycling Facility as often as necessary to determine compliance with the
permit requirement ofNC130008.
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]
����n �' �, City Council: Mayor Allen Ioines; Denise D. Adams, Mayor Pro Tempore, Nonh Ward; Barham Hanes Burke, Northeast Wazd; RobertC. Clark,
West Ward; John C. Larson, Sonth Ward; ]ef£Maclntosh, Northwest Ward; Kevin Mnndy, Southwest Ward; Annette Scippio, East Ward;
Call 311 or 336-727-8000 James Taylor, Jr., Southeast Ward; Cily Manager: Lee D. Garrity
dtylink@cityofws. org

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Stormwater/Erosion Control Division
Industrial and Municipal Good Housekeeping Inspection Form
General Information
A) Official Company Name: Republic Services
B) Physical Address: 2876 Lowery Street, Winston-Salem, NC 27101
C) Telephone Number: 336-714-4301(c)
D) Mailing Address, if different from above address: 2875 Lowery Street, Winston-Salem, NC 27101
E) Authorized contacts to represent entity in environmental regulatory issues:
Primary contact: Derek Bouchard
Title: Environmental Manager
Contact number(s): 314-302-3634(c)
Email address: [e-mail]
Secondary contact: Catherine Hernandez/Jorge Hernandez
Title: Operations Manager/General Manager
Contact number(s): 336-714-4301(c)/336-714-4300(c)
Email address: [e-mail]
F) Standard Industrial Classification (SIC) Number of business/operation (if applicable): 50
G) NC Stormwater NPDES Permit Number (if applicable}: NCG130008
Permit Category: Non -Metal Recycling
H) Any other control authority permits) (e.g. air quality control, wastewater, hazatdous waste) & number(s):
RCRA Small %Y Generator — NCD981859580
I) Brief description of facility activities that occur on -site::
Facility is a cardboard recycling facility. Cardboard products are brought onsite and loaded into
a hydraulic press where the recyclables are pressed and stored under cover until removal from the
facility. Some repurposed waste containers are stored at the facility.
I) Ultimate
Receiving Waters:
Salem
Creek
TMDL
stream
®Yes
❑No
If Yes, What Pollutants: Fecal & TSS
Part 1-Stormwater Controls
1. Best Management Praotices (BMPs)
a. List the controls tstructural ornon-structural) emnloved by the
E.g. Oil Water separators, cleaning schedules, structural BMP maintenance records
1. Primary industrial activities are under cover
2. Regular cleaning schedule
3. Specialty catch basin grates to reduce potential of debris reaching stormwater conveyance

b. Are the non-structural BMPs reasonable & appropriate for the facility? MYes ❑No
Facility showed no signs of trash build up or potential for pollutants to reach the
stormwater conveyances.
c. Are stormwater control measures (SCMs) installed correctly, maintained, and effective operating condition?
❑ Yes ❑ No (A N/A
No structural measures are maintained 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):
Catch basins at the facility have specialty grates that feature smaller access holes to prevent
cardboard debris from reaching the stormwater conveyances. All industrial processes are
performed under cover in a large warehouse.
Part 2 —Stormwater Discharge Outfalls (SDOs)
1. Any evidence of discharge to receiving waters/MS4 from the SDOs? (e.g.: stormwater runoff, dry weather
discharge, co -mingling of process wastewater, trash, debris, on and grease): ❑Yes ®No
Outfall
showed no signs
of illicit discharges, however, large amounts of erosion
were
present
at the on A
solution to the erosion should be evaluated and put in
place.
2) Do the stormwater outfalls on -site cortespond with those listed on the site map in the Stormwater Pollution
Prevention Plan(SWPPP)? ®Yes ❑No
Single outfall located near the entrance to the facility.

3) Summary of Stormwater Discharge Outfalls
SDO Identification
Potential Pollutants that
Physical Location
Latitude and
could be discharged
Longitude
if known
Outfall No. 1
TSS, Hydrocarbons,
Outfall to the west of the
Mv098, =80.195
Trash
entrance to the facility

Part 3 - BMP: Inspection and maintenance program
Yes N/A No Notes
Is secondary containment provided for materials (including
X
Single hydraulic press in
waste) or products stored outside in tanks and/or containers
the warehouse. A full
(where applicable)?
spill kit needs to be added
to the area.
Are secondary containment free of accumulated water, debris,
X
cracks, holes, or evidence of leaks?
Does the facility maintain secondary containment drain logs?
X
Do the drain logs confirm the presence of pollutants and other
X
pertinent information, such as signatory requirements, name of
secondary containment area, date, time, and if drainage is
connected to MS4 or receiving waters?
Are tanks and containers in good condition, closed, and
X
Hydraulic press was in
properly marked?
good shape with small
amounts of staining
around it.
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
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
needs to be added to spill
on a spill release form?
documentation for
reporting.
Any roof stacks that have the potential to release
X
solids/particulate?
Are all hazardous materials properly labeled and stored to
X
prevent exposure to stormwater runoff?
Are solid waste containers in good condition and of sufficient
X
Single waste container
size to contain all waste? If so, how is this determined?
near loading docks.
Do the solid waste containers have covers and closed drain
X
lugs?
Are solid waste containers free of waste that requires special
X
handling/disposal? Are containers properly labeled to ensure
correct disposal means?
Are solid waste containers labeled "Prohibited - No Hazardous
X
Waste, No Recyclable Materials, No Liquids?"
Are special containers provided for other types of waste? E.g.
X
liquid waste or hazardous waste
Does the facility utilize oil water separators? If yes, are the
X
inspection and maintenance records documented?
Are secondary containment drain valves maintained in the
X
closed position, unless the facility is draining the secondary
containment?

Part 4 — Stormwater Pollution Prevention Plan (SWPP) Review
Site Overview
Yes No Notes
Is there a SWPPP? Is it upAo-date?
X
Last official update 2018,
Regularly signed for
updates.
Does SWPPP include a certification statement by the responsible
X
Signed by Derek Bouchard
corporate officer?
Does the general map depict the facility's location on a USGS
X
Unnamed Tributary to
quad map (or equivalent map) with receiving waters (or MS4)
Salem Creek.
listed?
Identification of impaired waters or watershed (if applicable)?
X
Salem Creek is a TMDL
stream.
Narrative Description of these Industrial/Operational Activities:
SWPPP has good
Storage Practices
X
descriptions of all onsite
Unloading/Loading Activities
X
practices. Majority of
Outdoor Processes
X
industrial practices are
Particulate Generating/Control Processes
X
under cover. No vehicle or
Waste Disposal
X
equipment cleaning is
Vehicle/Equipment Washing
X
performed at the facility.
Does site map denote drainage items: flow direction, boundaries,
X
% impervious, and structures? Does the map also include SDOs,
industrial activity areas, and site topography?
A list of major spills that have occurred within the past three years
X
with corrective actions to prevent futures ills ?
A signed, annual certification that the facility has been tested for
X
non-stomiwater discharges from the site?
Comments:
SWPPP is well put together and describes all processes completed at the
facility. Facility is used sporadically and description of practices covers the
sporadic use. Facility could lead to impacts of TMDL status in Salem Creek
due to large amount of erosion at Outfall No. 1. Outfall erosion should be
fixed in order to reduce the potential for impacts to the TMDL stream. Keith
Huff's information needs to be added to spill reporting list. The City of
Winston-Salem's stormwater division should be contacted when spills occur
at the facility.

Stormwater Management Strategy
Yes No Notes
Does SWPPP incorporate the nine baseline controls:
X
X
Feasibility Study (technical & economic review to minimize pollutant exposure)
Secondary Containment (table summary of tanks, stored materials, release records)
X
None at facility.
X
Cleaning schedule
BMP Summary (listing of site structural/nonstructural practices)
documented,
X
PM & GH (inspection of material handling areas & regular cleaning schedules)
X
Done monthly.
Facility Inspections (biannual inspections of facility and all stormwater systems,
were the inspections completed during separate parts of the year?)
Employee Training (annual basis for staff who perform SPRP and GH functions)
X
X
Responsible Party (specific position(s)/person(s)-developing, implementing, &
revising SWPPP)
Amendment & Annual Update (of major spills, non-sw flows, BMPs, sampling data)
X
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
No major spills have occurred
releases? Does the entity properly dispose of contaminated materials
used in the clean up? Is the disposal of materials documented? Has a
contact person(s) and contact information been identified and
at the facility. Some oil -dry
has been used sporadically for
hydraulic press leaks.
documented for each facility?
Analytical Monitoring (f not applicable, please notate)
Yes No Notes
Are samples collected within 30 minutes of the first discharge from
N/A
a measurable rain event and at least 72 hours since the last storm
event?
Are sampling events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
N/A
Is analytical monitoring complete (including schedule) for each
N/A. No vehicle
SDO? (EXCEPTION: REPRESENTATIVE OUTFALL STATUS)
maintenance done on site
therefore no analytical
sampling is required by the
NCG13 permit.
N/A
Any exceedances of pollutant parameters when compared against
the permit benchmark values? If yes, have they documented their
response to the Department of Environmental Quality?
N/A
Has the facility implemented appropriate, selected actions to
reduce pollutant concentrations, in response to benchmark
exceedances (if applicable)?

Qualitative Monitoring
Yes No Notes
Is qualitative monitoring being performed during measurable storm
X
events?
Is qualitative monitoring complete (including schedule) for each
X
SDO?
Are monitoring events 60 days apart? (EXCEPTION: Tier 2 & 3 responses)
X
X
Qualitative monitoring has
Any observable, excessive amounts of pollutant indicators in
mentions of erosion issues
stormwater discharge at SDOs?
at outfall but also described
a fix for the erosion issues
in the comments.

Part 5 — Required Actions to be completed by Facility:
Items to be completed within 3 months of receipt of this report:
1) The scrapped containers located at the facility must be cleaned more thoroughly and any trash
and debris that remains needs to be removed prior to being placed at the facility. (Photo 1)
2) A solution to the erosion at the outfall must be evaluated and a plan of action must be
implemented in order to prevent the potential impacts to the TSS TMDL of Salem Creek. (Photo 2)
3) A full spill kit must be added to the facility near the hydraulic press.
4) Keith Huff's information must be added to the spill response procedures in the S WPPP. The
City of Winston-Salem's stormwater division must be notified during a spill at the facility. Keith
Huff s information is:
Keith Huff
Director of Field Operations
336-747-6962
[e-mail]
Entity Representatives) that participated in inspection: Derek Bouchard
Title(s): Environmental Manager
Start of Inspection: 9:55 am
Completion of Inspection: 10:30 am
Date: January 15, 2021
Signature of Inspector:
Title: Stormwater Inspector

Photo 1—Broken down waste containers being stored at the facility.
The scrapped containers located at the facility should be cleaned more thoroughly
and any trash and debris that remains should be removed prior to being placed at the
facility.