WSTA _MGH Inspection Package_6_21_22

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Winston�salem
Field Operations
Stont water Division
City of Winston-Salem
P.O. Box 2511
Winston-Salem, NC 27102
CityLink 336.727.8000
June 21, 2022
John Ashford
Assistant General Manager Winston-Salem Transit Authority
1060 Trade St NW
Winston-Salem, NC 27101
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 June 14, 2022, 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 # 1-22
that WSTA must complete. Please provide documentation that verifies WSTA
successfully completed the corrective measures to me by September 21, 2022.
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,
Ladonta Clark (Jamal)
Stormwater Operations Supervisor
City of Winston Salem
Stormwater Division
Field Operations Department
Phone: [phone]
Cell: 336.416.2403
Call 311 or 336-727-8000
c i ty l i nk@c ityofws. o rg
City Council: Mayor Allen Joines; Denise D. Adams, Mayor Pro Tempore, North Ward; Barbara Hanes Burke, Northeast Ward; Robert C. Clark,
West Ward; John C. Larson, South Ward; Jeff Macintosh, Northwest Ward; Kevin Mundy, Southwest Ward; Annette Scippio, East Ward; James
Taylor, Jr., Southeast Ward; Lee D. Garrity, City Manager

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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: 336-727-2006 (Office)
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): 336-727-2006 (Office)
Email address: [e-mail]
Secondary contact: John Ashford
Title: Assistant General Manager/Maintenance Manager
Contact number(s): 336-727-2006 (Office)
Email address: [e-mail]
F) Standard Industrial Classification (SIC) Number of business/operation (if applicable): 4111 Local and
Suburban Transit
G) NC Stormwater NPDES Permit Number (if applicable): NCG080023
Permit Category: Transit and Transportation
H) Any other control authority permit(s) (e.g. air quality control, wastewater, hazardous waste) & number(s):
NCD981859424- RCRA (Please confirm)
I) Brief description of facility activities that occur on -site:
WSTA is used as for performing of maintenance on city buses and storing bus parts. WSTA a
parking lot for all fleet busses parking. Lastly, WSTA has large wash bay for the washing of vehicles.
I) Ultimate Receiving Waters: Peters Creek
TMDL stream ❑Yes ®No If Yes, What Pollutants:
Part 1 - Stormwater Controls
1. Best Management Practices (BMPs)
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
Comments
WSTA uses oil pans for buses that have leaks while disposing of the old fluids properly.
c. Are stormwater control measures (SCMs) installed correctly, maintained, and effective operating condition?
❑Yes ❑ No ® N/A
Comments
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/MS4 from the SDOs? (e.g.: stormwater runoff, dry weather
discharge, co -mingling of process wastewater, trash, debris, oil and grease): ❑Yes ®No
Comments
2) Do the stormwater outfalls on -site correspond with those listed on the site map in the Stormwater Pollution
Prevention Plan (SWPPP)?
Comments
©Yes ❑No
The site of WSTA will need to have the impervious percentage of the property added to the
map to meet the permit requirements.

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 & Gl•ease, Wash
Curb inlet to the south of
36.107163,-80.248522
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
waste) or products stored outside in tanks and/or containers
(where applicable)?
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
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
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
facility maintain and submit documentation to the City of WS
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
prevent exposure to stormwater runoff?
Are solid waste containers in good condition and of sufficient
x
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
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 closed
x
position, unless the facility is draining the secondary containment?

Site Overview
Part 4 — Stormwater Pollution Prevention Plan (SWPP) Review
Yes No Notes
Is there a SWPPP? Is it up-to-date?
x
Updated in 2022
Does SWPPP include a certification statement by the responsible
x
Updated in 2022
corporate officer?
Does the general map depict the facility's location on a USGS
x
quad map (or equivalent map) with receiving waters (or MS4)
listed?
Identification of impaired waters or watershed (if applicable)?
x
Narrative Description of these Industrial/Operational Activities:
Storage Practices
x
Unloading/Loading Activities
x
Outdoor Processes
x
Particulate Generating/Control Processes
x
Waste Disposal
x
Vehicle/Equipment Washing
x
Does site map denote drainage items: flow direction, boundaries,
x
Site map needs the
% impervious, and structures? Does the map also include SDOs,
impervious percentage
industrial activity areas, and site topography?
added to it
A list of major spills that have occurred within the past three years
x
Please document
(with corrective actions to prevent futurespills)?
A signed, annual certification that the facility has been tested for
x
Updated in 2022
non-stormwater discharges from the site?
Comments
Samples shall be collected from four separate monitoring periods per year unless the
facility is in Tier Two or Tier Three status. A minimum of 30 days must separate any
two sampling events during the following periods:
i. January 1— March 31
ii. April 1— June 30
;ii. July 1— September 30
iv. October 1— December 31
With the new permit WSTA must at least sample four times a year now compared to
twice a year with the past permits.

• Sample results shall be recorded on Discharge Monitoring Report (DMR) forms
provided by the Director. DMR forms are available on the Division's website:
https://deci.nc.gov/about/divisions/energy-mineral-land-resources/npdes-
industrial-stormwater
• If no discharge occurs during the sampling period, the permittee must record
within 30 days of the end of the sampling period in the facility's monitoring
records. "No Flow" or "No Discharge" shall be reported on the Discharge
Monitoring Report (DMR).
• (a) Visual inspections shall be made at each stormwater discharge outfall
(SDO) that discharges stormwater associated with industrial activity unless
representative outfall status specifically for visual monitoring has been approved
in writing by the Division.
• (b) Visual inspections shall be performed concurrent with required analytical
monitoring.
• (c) Visual inspections are not required to be performed outside of the
facility's normal operating hours.
• (d) Visual inspections shall be recorded on the Division's Stormwater
Discharge Outfall Qualitative Monitoring Report (QMR) form and shall include
observations of:
• i. Color
• ii. Odor
• iii. Clarity
• iv. Floating Solids
• V. Suspended Solids
• vi. Foam
• vii. Oil Sheen
• viii. Deposition at or immediately below the outfall
• ix. Erosion at or immediately below the outfall, and
• X. Other obvious indicators of stormwater pollution.
• (e) Inability to perform inspections because of adverse weather or lack of
discharge during the monitoring period shall not constitute a failure to monitor if
the event is documented in the SWPPP and recorded on the QMR.

Stormwater Management Strategy
Yes No Notes
Does SWPPP incorporate the nine baseline controls:
x
Feasibility Study (technical & economic review to minimize pollutant exposure)
x
Secondary Containment (table summary of tanks, stored materials, release records)
BMP Summary (listing of site structural/nonstructural practices)
PM & GH (inspection of material handling areas & regular cleaning schedules)
Facility Inspections (biannual inspections of facility and all stormwater systems,
were the inspections completed during separate parts of the year?)
x
x
x
x
Employee Training (annual basis for staff who perform SPRP and GH functions)
Responsible Party (specific position(s)/person(s)-developing, implementing, &
revising SWPPP)
x
x
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
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
documented for each facility?
Analytical Monitoring (if not applicable, please notate)
Yes No Notes
Are samples collected within 30 minutes of the first discharge from
X
No samples have been
a measurable rain event and at least 72 hours since the last storm
collected since 2021
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)
X
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
No monitoring has been
events?
performed since 2021
Is qualitative monitoring complete (including schedule) for each
X
SDO?
Are monitoring events 60 days apart? (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:
1. Due to the recent weather events, please replace the pillow absorbent pads at SDO #1.
2. Due to recent weather events please replace the pillow absorbent pads at the catch basin
across from SDO #1.
3. Please clean up the oil leak at parking space number 59 to prevent further mixing of the
elements.
4. Please clean up excess dirt that has accumulated at parking space number 3990 to prevent
further mixing of the elements.
5. Please replace the existing bucket that is used for oil sorb at the fuel station near SDO #1.
Also, ensure that the new bucket has a lid to protect the oil sorb from the outside elements.
6. Please add the impervious percentage of the property to site map.
7. Please notate where both locations are for vehicle washing on the site map as industrial
activity areas.
8. Since WSTA has not had any spills within the past three years please document that WSTA
has not had any significant spills in the past three years. Because of the new permit changes,
ensure WSTA makes a documentation for each separate year to specify the years instead of
combining them together.
9. Please determine if WSTA needs a feasibility study and create it. If WSTA does not need one,
please document that WSTA doesn't need one and add it to the SPPP.
10. Please provide an updated summary of tanks and stored material equipped with secondary
containment systems. If WSTA doesn't have it, please provide storage with amounts as well.
11. Please provide a BMP summary which at a minimum shall include: (a) Written record of the
specific rational for installation and implementation of the selected site BMPs (b) Structural
and nonstructural practices to minimize the exposure and transport of materials in
stormwater; BMPs for vehicle maintenance activities; and remote fueling.

12. Concerning the BMPs for vehicle and equipment leaning areas, please ensure that the plan
describe measures that prevent or minimize contamination of the stormwater runoff from all
areas used for vehicle and equipment cleaning. At a minimum that plan must include the
following considerations: (a) Performing all cleaning operations indoors; (b) Covering the
cleaning operations; (c) Ensuring that all wash waters drain to the sanitary sewer system (i.e.,
not the stormwater drainage system, unless permitted by another NPDES general or
individual permit); (d) Collecting the stormwater runoff from the cleaning area; and (e)
Providing treatment or recycling, or other equivalent measures.
13. Since the permit has made updates to the type of employee training that is conducted, please
perform employee training at a minimum that includes (a) General stormwater awareness; (b)
The provisions of the current NCG080000 general permit. (c) Spill response training; (d) Used
oil management; (e) Spent solvent management; (f) Secondary containment releases; (g)
Fueling procedures; (h) Disposal of spent abrasives; and (i) Used battery management.
14. Please create a Spill Prevention and Response Procedures (SPRP) that includes An
assessment of areas of the facility where there is the potential for spills; (b) a list of trained
facility personnel responsible for implementing the SPRP; (c) A signed and dated
acknowledgement in which staff members accept responsibilities for the SPRP; (d) An
inventory of spill response materials and equipment and the locations for storing these items;
(e) Written procedures for proper cleanup and disposal of spilled materials; and (f) A list of
significant spills or leaks of pollutants that have occurred during the previous three (3) years
and any corrective actions taken to mitigate spill impacts, or the notation that no spills have
occurred. This list shall be updated on an annual basis.
15. Please generate a solvent management plan specific to WSTA. The Solvent Management Plan
(SMP) shall be incorporated as a separate chapter into the SWPPP. The SMP shall include (a)
An annually updated and quantified inventory of solvents present on site during the previous
three (3) years; (b) A narrative description of the facility locations and uses of solvents; (c) The
method of disposal, including quantities disposed on -site and off -site; and (d) The management
procedures and engineering measures for assuring that solvents do not spill or leak into
stormwater.

16. Please give a brief description of operation and maintenance of treatment and control systems
for all oil water sand separators on site and include this in the (SWPPP)
17. Please provide emails that have been conducted between WSTA and PACE that shows the
progression of finding another vendor. Also save a DMR form for missing sampling periods.
For periods were missed.
18. Since Pace has sent a quote for how much it would cost to perform the NCG08000 sampling on
site at WSTA please continue to move forward with a contract. Please store a copy of the
NCG08000 sampling quote in the SWPPP. Once that contract is provided, please provide the
documentation, and include a copy of that quote in the SWPPP.
19. Please document all sampling the periods that WSTA has missed due to not having a current
sampling contract. Also, please document each missed sampling period on a DMR form and
store all information in the SWPPP.
20. On the storage tank maps, please update the tanks and stored materials that are equipped
with secondary containment systems to list the type of material along with the amount stored
in each tank.
21. Please update the entire secondary containment plan to match the current permit cycle which
runs in-between July 1, 2021, June 30, 2026, that WSTA is currently operating under.
22. Please confirm how WSTA is listed on the RCRA website. Once that has been confirmed,
please document the new findings in the SWPPP and provide Stormwater staff with the new
information.

Part 6 —Action Items Completed that reduce pollutants:
How many action items were recommended that will reduce pollutants? 9
Entity Representative(s) that participated in inspection: John Ashford
Title(s): General Manager/Maintenance Manager
Start of Inspection: 12:15pm
Completion of Inspection: 2:15pm
Date: Jun 14, 2022
Signature of Inspector:
Title: Stormwater Operations Supervisor

Picture # 1 SDO #1 Absorbent pads exposed to the past storm event
Due to the recent weather events, please replace the pillow absorbent pads at SDO
#1.
Picture # 2 Catch basin across from SDO #1 with absorbent pads exposed to the
past storm event
Due to recent weather events please replace the pillow absorbent pads at the catch
basin across from SDO #1.

Picture # 3 Small oil stain at parking space number 59
Please clean up oil leak at parking space number 59 to prevent the further mixing
of the elements.
Picture # 4 Excess dirt build up at parking space number 3990
Please clean up excess dirt that has accumulated at parking space number 3990 to
prevent further mixing with the elements.

Picture # 5 Spill kit bucket that has chipped pieces of the top of the bucket broken
off with no lid on the top of the bucket
Please replace the existing bucket that is used for oil sorb at the fuel station near
SDO #1. Also, ensure that the new bucket has a lid to protect the oil sorb from the
outside elements.