NCG140170_Inspection Report (City of WS)_20210408

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December 10, 2020
astonsolem Danny Rathbone
Field Operations Operations Manager
Stonnwater Division Argos USA, LLC
1590 Williamson Street
Cityorwinston-sales, Winston-Salem, NC 27107
EO. Box 2511
Winston-Salem, NC 27102
CityLink 336.727.80DD Dear Mr. Rathbone:
The Stormwater Division of the City of Winston-Salem would like to thank you for
your time and professional courtesy regarding the December 4, 2020 inspection of
Argos USA, LLC — Clemmonsville Road Plant.
Asper your request, 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 Argos USA must complete. Please provide documentation
that verifies Argos USA successfully completed the corrective measures to me by
February 15, 2021. Part 5 of this report also contains Annotation #1-2 that Argos
USA must complete. Please provide documentation that verifies Argos USA
successfully completed the corrective measure to me by June 15, 2021.
The Stormwater Division reserves the right to enter Argos USA., LLC —
Clemmonsville Road Plant as often as necessary to determine compliance with the
permit requirement of NCG140170.
Thank you for your continued support of the City ofWinston-Salem's Stormwater
Program. If you have any questions, please feel free to contact me.
Sincerely,
Brando ise, CESSWI
Stormwater Inspector
Office: [phone]
Cell: [phone]
E-Mail: [e-mail]
CC: Robbie Potts &Steve Simonsen (via E-Mail)
x, � �� �, � �� �� �" City Coancil: Mayor Allen Joines; Denise D. Adams, Mayor Pro Tempore, North Ward; Darbara Hanes Burke, Northeast Ward; Robert C. Clark,
West Ward; John C. Larson, Sonth Ward; IenMaclnlosh, Northwest Ward; Kevin Mmdy, Sonfhwest Ward; Anneite Scippio, Easl Ward;
Call 311 or 336-727-6000 James Taylor, Jr., Southeast Ward; City Manager. Lee D. Gamily
[e-mail]

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RinslonSelem
Stormwater/Erosion Control Division
Industrial and Municipal Good Housekeeping Inspection Form
General Information
A) Official Company Name: Argos USA, LLC
B) Physical Address: 2439 Clemmonsville Road, Winston-Salem, NC 27127
C) Telephone Number: 336-659-5620(0)
D) Mailing Address, if different from above address: 1590 Williamson Street, Winston-Salem, NC 27107
E) Authorized contacts to represent entity in environmental regulatory issues:
Primary contact: Danny Rathbone
Title: Operations Manager
Contact number(s): 336-345-8304(e)
Email address: [e-mail]
Secondary contact: Steve Simonsen
Title: Environmental Manager
Contact number(s): 770-356-7285(c)
Email address: [e-mail]
F) Standard Industrial Classification (SIC) Number of business/operation (if applicable): 3273
Ready -Mix Concrete Production
G) NC Stormwater NPDES Permit Number (if applicable): NCG140170
Permit Category: Ready -Mix Concrete Batch Plants
H) Any other control authority perrnit(s) (e.g. air quality control, wastewater, hazardous waste) & number(s):
Air Quality — 00452R5 (permitted through Forsyth County Local Program)
I) Brief description of facility activities that occur on -site:
Raw materials are delivered to the plant and stored. Materials and water are fed to concrete
mixer trucks and delivered to the customer. Any unused concrete is returned and poured into block
molds or crushed into aggregate. Fueling and washing of truck drums is also done on site.
I) Ultimate Receiving Waters: Salem Creek
TMDL stream ®Yes ❑No If Yes, Pollutant of Concern: Fecal Coliform
Part 1 -Stormwater Controls
Best Management Practices (BMPs)
List the controls (structural or non-structural) emnloved by the
E.g. Oil Water separators, cleaning schedules, structural BMP maintenance records
1. Settling basins at low point for collection of Stormwater prior to reaching pond.
2. Stormwater pond, which has a water recycling system
3. Regular facility inspections
4. Earthen berm to direct water to SCMs rather than to stormwater conveyance
5. Stormwater recycling system

b. Are the non-structural BMPs reasonable & appropriate for the facility? ® Yes ❑No
Facility inspections are completed on a regular basis and records are kept in the office.
Comingled stormwater and process wastewater from the pond is recycled to mix with
concrete to help prevent discharges from the facility.
c. Are stormwater control measures (SCMs) installed correctly, maintained, and effective operating condition?
®Yes ❑ No ❑ N/A
SCMs at the facility are regularly cleaned out to prevent sediment build up. The small
ponds are cleaned out weekly with the larger pond cleaned out once every six months. The
largest pond on site is cleaned out as needed. Measures should be put in place to prevent
floating solids, like the fly ash observed on site, from reaching the large pond.
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 stormwater conveyance that runs through the site has catch basins that are raised or in areas
of no flow to prevent industrial stormwater from reaching the drains.
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
Floating
solids. were present in
the first sediment basin and
must be removed; however, no
evidence
was seen of the solids
reaching the discharge point
in the pond.
2) Do the stormwater outfalls on -site correspond with those listed on the site map in the Stormwater Pollution
Prevention Plan(SWPPP)? ®Yes ❑No
The facility has a single outfall located at the discharge point of the stormwater wet pond.

3) Summary of Stormwater Discharge Outfalls
SDO Identification
Potential Pollutants that
Physical Location
Latitude and
could be discharged
Longitude
(if known
Outfall 001
pH, TSS, Oil & Grease,
Eastern edge of facility at
36.03333, =80.32
Concrete Admixtures
pond discharge.
from tank farm

Part 3 - BMP: Inspection and maintenance program
Yes N/A No Notes
Is secondary containment provided for materials (including
X
Totes near secondary
waste) or products stored outside in tanks and/or containers
containment need to be
(where applicable)?
placed in the secondary
containment. The
containment for the tanks
is cracked.
Are secondary containment free of accumulated water, debris,
X
Containment is cracked
cracks, holes, or evidence of leaks?
and has debris/sediment
in it.
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
properly marked?
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
Fuel tank has concrete
vehicles and equipment? E.g. bollards and curbs
bollards, other tanks are
on raised platform with
concrete wall.
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
Ensure City of Winston -
facility maintain and submit documentation to the City of WS
Salem is added to
on a spill release form?
reporting list.
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 dumpster on site.
size to contain all waste? If so, how is this determined?
Do the solid waste containers have covers and closed drain
X
plugs?
Are solid waste containers free of waste that requires special
X
Ensure waste dumpster is
handling/disposal? Are containers properly labeled to ensure
properly labeled.
correct disposal means?
Are solid waste containers labeled "Prohibited - No Hazardous
X
Ensure waste dumpster is
Waste, No Recyclable Materials, No Liquids?"
labeled.
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
Locking mechanism
closed position, unless the facility is draining the secondary
should be added to
containment?
bottom drain valve.

Part 4 — Stormwater Pollution Prevention Plan (SWPP) Review
Site Overview
Yes No Notes
Is there a SWPPP? Is it up-to-date?
X
Facility copy is updated
Does SWPPP include a certification statement by the responsible
X
Signed by Melissa Swanson.
corporate officer?
Does the general map depict the facility's location on a USGS
X
Salem Creek must be
quad map (or equivalent map) with receiving waters (or MS4)
designated as a TMDL
listed?
stream.
Identification of impaired waters or watershed (if applicable)?
X
Facility map has TMDL
designation listed however
it must be added to USGS
map as well.
Narrative Description of these Industrial/Operational Activities:
Storage practices,
Storage Practices
X
unloading/loading activities,
Unloading/Loading Activities
X
waste disposal, and
Outdoor Processes
X
particulate generating
Particulate Generating/Control Processes
X
practices are well defined.
Waste Disposal
X
Outdoor process are all
Vehicle/Equipment Washing
X
X
processes on site so general
description of activities will
count for this section.
Vehicle/Equipment washing
is mentioned in the SWPPP
however more detail is
re aired.
Does site map denote drainage items: flow direction, boundaries,
X
Single outfall on site, site
% impervious, and structures? Does the map also include SDOs,
information in top left
industrial activity areas, and site topography?
corner of facility site map.
A list of major spills that have occurred within the past three years
X
Facility personnel informed
(with corrective actions to prevent future spills)?
stormwater inspector that a
list was kept however they
were not able to locate it
during the inspection.
A signed, annual certification that the facility has been tested for
X
Yearly updates kept in 3
non-stormwater discharges from the site?
ring binders at the office.
Comments:
SWPPP is well put together and is site specific. All Inspection records,
sampling records, and certification statements are kept in the office at the
facility and are very well organized. SWPPP needs to have the spill list kept
with it and more detail about on site vehicle washing.

Stormwater Management Strategy
Yes No Notes
Does SWPPP incorporate the nine baseline controls:
X
Feasibility Study (technical & economic review to minimize pollutant exposure)
X
Feasibility Study must be
incorporated into SWPPP.
X
Tanks are mentioned but
Secondary Containment (table summary of tanks, stored materials, release records)
need to be listed in the
SWPPP
X
Cleaning and inspections are
BMP Summary (listing of site structural/nonstructural practices)
mentioned make sure the
schedule is documented in
SWPPP.
PM & GH (inspection of material handling areas & regular cleaning schedules)
X
Inspection records are kept in
Facility Inspections (biannual inspections of facility and all stormwater systems,
a binder at the facility.
X
Inspection records are kept in
were the inspections completed during separate parts of the year?)
binder.
Employee Training (annual basis for staff who perform SPRP and GH functions)
X
Annual training
documentation is kept in
binder.
X
Responsible party and spill
team is documented in
SWPPP.
Responsible Party (specificposirion(s)/person(s)-developing, implementing, &
revising SWPPP)
X
Make sure spill list is kept in
binder with the other
Amendment & Annual Update (of major spills, non-sw Flows, BMPs, sampling data)
certifications.
Does SWPPP contain completed routine inspection reports/records
X
Inspections are done
regarding reportable implementation of the nine baseline controls
regularly and records are
e.g. SWPPP Implementation)?
kept in the binder.
Does the Spill Response Procedures (SPRP) document all spills and
X
Ensure spill records are kept
releases? Does the entity property dispose of contaminated materials
with SWPPP even if the list is
used in the clean up? Is the disposal of materials documented? Has a
contact person(s) and contact information been identified and
just an annual signing off
saying no spills occurred.
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
X
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)
X
Is analytical monitoring complete (including schedule) for each
X
SDO? (EXCEPTION: REPRESENTATIVE OUTFALL STATUS)
Any exceedances of pollutant parameters when compared against
X
Facility is currently in
the permit benchmark values? If yes, have they documented their
Tier 0' Status.
response to the Department of Environmental Quality?
N/A. It should be noted
that should the facility wish
to just collect process
Has the facility implemented appropriate, selected actions to
wastewater samples that
reduce pollutant concentrations, in response to benchmark
would be compliant with
exceedances (if applicable)?
the permit since all
stormwater at the facility is
comingled with process
wastewater.
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 a art? (EXCEPTION: Tier 2 & 3 responses)
X
X
Any observable, excessive amounts of pollutant indicators in
stormwater discharge at SDOs?

Part 5 — Required Actions to be completed by Facility:
Items to be completed within 2 months of receipt of this report:
1) Signage must be added to door near fueling area stating the location of the spill kits. (See Photo
1)
2) Manufactured sand must be moved to ensure runoff from the storage area goes to the monitored
outfall. (See Photo 2)
3) Old tanks that are no longer in use must be removed from the facility. Tanks at the facility were
observed near the water recycling system and at the rear of the facility near the boneyard. (See
Photos 3 & 4)
4) Remove all totes along with the unknown liquids in the totes. Ensure the liquids are disposed of
properly according to the state and federal guidelines. (See Photo S)
5) Berm located near the stormwater pond should be brought back up to the height of the rest of the
berm to ensure stormwater does not reach the catch basin in the grass and get discharged to the
MS4 system. (See Photo 6)
6) Implement a permanent solution to prevent floatable solids and hydrocarbons from reaching the
sediment basins. During the inspection what appeared to be fly ash was present in the basins. (See
Photo 7 & 8)
7) Implement an inspection schedule and cleaning schedule for hydrocarbon leaks located at the silo
areas. Ensure the solution to prevent floatable solids will also absorb hydrocarbons. The leak noted
must be cleaned up as soon as possible. The facility should evaluate the current inspection and
cleaning schedule of the silo area to determine if the frequency is adequate to prevent stormwater
pollution. (See Photo 9)
8) Implement a good housekeeping measure to ensure the red hose from the polymer tote is placed
inside of an approved secondary containment to prevent accidental release. (See Photo 10)
9) Remove scrap metal located near the boneyard in order to prevent stormwater pollution. (See
Photo 11)
10) Evaluate the old plant materials for removal from the facility. Provide the City's Stormwater
Division details of what will occur with the materials. If removed provide proper documentation of
the removal. (See Photo 12)
11) Add Keith Huff s contact information to spill reporting list. Should a spill occur Keith Huff
must be contacted to inform the City's Stormwater Division of the spill. (Phone: [phone], E-
Mail: [e-mail], Title: Director of Field Operations)
12) Add proper labeling to the small dumpster at the facility denoting what materials are allowed to
be removed via the dumpster.
13) Update USGS map to properly identify Salem Creek and properly designate it as a TMDL
stream.
14) Update facility's SWPPP to include details about vehicle/equipment washing, a feasibility
study, a proper table listing all tanks on site, and the schedule for inspecting and cleaning the
facility.
15) If the facility is unable to locate the spill list along with certifications of no spills, this list must
be added to the S WPPP records kept at the office.

Items to be completed within 6 months of receipt of this report:
1) Fix the secondary containment at the tank farm area. The secondary containment has large
cracks that prevent the containment from operating as designed. Please ensure that the City of
Winston-Salem Stormwater Division receives email updates during the process of fixing the
containment. (See Photos 13 & 14)
2) Once secondary containment has been fixed, ensure a locking mechanism is added for any
bottom drains.
Entity Representatives) that participated in inspection: Danny Rathbone &Robbie Potts
Title(s): Operations Manager & Facility Manager
Start of Inspection: 9:00 am
Completion of Inspection: 11:30 am
Date: December 4, 2020
Signature of Inspector:
Title: Stormwater Inspector

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Photo 2 — Mauufachu•ed sand stored near the entrance to the facility.
Manufactured sand must be moved to ensure runoff from the storage uea goes to the
monitored outfallI

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Photo 5 —Totes with unknown liquid in them located near the boneyard.
Remove all totes along with the unknown liquids in the totes. Ensure the liquids are
disposed of properly according to the state and federal guidelines.

Photo 6—Low spot in beam caused by large rain event.
Berm located near the stormwater pond should be brought back up to the height of the rest
of the berm to ensure stormwater does not reach the catch basin in the grass to be
discharged to the MS4 system.

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Photo 8 —Apparent floatable solids and hydrocarbons visible in the settling pond.
Implement a permanent solution to prevent floatable solids and hydrocarbons from
reaching the sediment basins. During the inspection what appeared to be fly ash was
present in the basins

Photo 9 —Hydrocarbon leaks observed at silo loading area.
Implement an inspection schedule and cleaning schedule for hydrocarbon leaks located at the
silo areas. Ensure the solution to prevent floatable solids will also absorb hydrocarbons. The
leak noted must be cleaned up as soon as possible. The facility should evaluate the current
inspection and cleaning schedule of the silo area to determine if the frequency is adequate to
prevent stormwater pollution.

Photo 10 —Hose connected to the polymer tank placed on the ground outside of a BMP.
Implement a good housekeeping measw•e to ensure the red hose from the polymer tote is
placed inside of an approved secondary contaimnent to prevent accidental release.

Photo Il —Scrap metal located in the rear of the facility near the boneyard.
Remove scrap metal located near the boneyard in order to prevent stormwater pollution.

Photo 12 —Materials and structures from the previous concrete batch plant on site.
Evaluate the old plant materials for removal from the facility.

Photo 13—Tank farm with secondary containment.
Fix the secondary containment at the tank farm area. The secondary containment has large
cracks that prevent the containment from operating as designed. Please ensure that the City
of Winston-Salem Stormwater Division receives email updates for milestones completed
during the process of fixing the containment.

CONFIN
ENTRY
Photo 14 —Large vertical crack in the secondary containment.
Fix the secondary containment at the tank farm area. The secondary containment has large
cracks that prevent the containment nom operating as designed. Please ensure that the City of
Winston-Salem Stormwater Division receives email updates for milestones completed during
the process of fixing the containment.