NCG200532_Applicaiton_20210331

NC&-?Z0 532Z
NDivision of Energy, Mineral, and Land Resources
Land Quality Section
- National Pollutant Discharge Elimination System
Environmental
Quality NCG200000
NOTICE OF INTENT
FOR AGENCY USE ONLY
Date Received
Year
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Certificate of Coverer e
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National Pollutant Discharge Elimination System application for coverage under General Permit
NCG200000 for STORMWATER DISCHARGES associated with activities classified as:
SIC 5093 Scrap Metal Recycling (except as specified below),
And, Like activities deemed by DEMLR to be similar in the process, or the exposure of raw
materials, intermediate products, final products, by-products, or waste materials.
The following activities are excluded from coverage under this General Permit:
Automobile Wrecking for Scrap (a portion of SIC 5093) ECENED
= Non -Metal Scrap Recycling (a portion of SIC 5093) MAR 31 1021
• Used Motor Vehicle Parts (SIC 5015) DENR-L.ANID QUALITY
(Please print or type) STORMWATER PERMITTING
1) Mailing address of the owner/operator (address to which official permit correspondence will be mailed):
Name Metallum Recycling, LLC.
Owner Contact
Street Address
City
Telephone No.
E-mail Address
Ivan Zhao
P.O. Box 1199
Benson
State NC ZIP Code 27504
[phone] Fax:
[e-mail]
2) Location of the facility producing the discharge:
Facility Name
Facility Contact
Street Address
City
County
Telephone No.
Email
Metallum Recycling, LLC.
Danny Yu
1459 U.S. 117 South
Warsaw
State NC ZIP Code 28398
Duplin
[phone] Fax:
[e-mail]
3) Physical Location Information:
Please provide a description of how to get to the facility (use street names, state road numbers, and distance
and direction from a roadway intersection). 1-40 / Exit 369 / Turn Right, 1 mile down the road, to the right.
(A copy of a county map or USGS quad sheet with facility clearly located on the map is a required part of this application.)
4) Latitude 34° 57' 36.7272"
Longitude -78' 4' 40.0218" (degrees, minutes, seconds)
5) This NPDES Permit Application applies to which of the following :
❑ New or Proposed Facility* Date operation is to begin
❑✓ Existing
*if this new or proposed facility is located in one of the 20 coastal counties, please contact the appropriate DEMLR Regional
Office (see page 4) to determine if a State Stormwater Permit is required prior to construction.
Page 1 of 5
SWU-235-012815 Last revised 1/28/15

Practices
for
1459
Warsaw, NC 1'
Page I 1

Table of Contents
MANAGEMENT APPROVAL.......................................................................................................4
INTRODUCTION............................................................................................................................ 5
CHAPTER 1 GENERAL INFORMATION....................................................................................6
1.1 Facility Locations.................................................................................................................. 6
1.2 USGS Coordinates.....................................................................................................................6
1.3 Emergency Contacts..................................................................................................................6
1.4 Type of Industry.........................................................................................................................6
1.5 SIC Codes..................................................................................................................................6
1.6 EPA Hazardous Waste Identification Number..........................................................................6
1.7 Operating Schedule....................................................................................................................6
1.8 Facility Security.........................................................................................................................6
CHAPTER 2 STORM WATER BEST MANAGEMENT PRACTICES (BMP)
PLAN...............................................................................................................................................7
2.1 ORGANIZATION.....................................................................................................................7
2.1.1. Pollution Prevention Team....................................................................................................7
2.1.2 Existing Environmental Plans.................................................................................................9
2.2 SITE ASSESSMENT...............................................................................................................10
2.2.1 Site Analysis and Description of Exposed Materials............................................................10
2.2.2 Materials Inventory...............................................................................................................11
2.2.3 Past Spills and Leaks Identification......................................................................................11
2.2.4 Non -Storm Water Discharge Identification..........................................................................11
2.2.5 Storm Water Monitoring Data..............................................................................................11
2.2.6 Site Summary........................................................................................................................12
2.3 BMP IDENTIFICATION........................................................................................................12
2.3.1 Good Housekeeping..............................................................................................................12
2.3.2 Preventative Maintenance.....................................................................................................13
2.3.3 Visual Inspections.................................................................................................................13
2.3.4 Spill Prevention and Response..............................................................................................14
2.3.5 Erosion and Sediment Control..............................................................................................14
2.3.6 Management of Runoff ...................................
2.3.7 Employee Training ..........................................
2.3.8 Recordkeeping and Reporting .........................
2.3.9 Advanced Best Management Practices...........
......................................................................14
......................................................................15
......................................................................15
15
2.4 PLAN IMPLEMENTATION..................................................................................................16
2.4.1 Appropriate Controls............................................................................................................16
2.4.2 Employee Training................................................................................................................17
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2.5 PLAN EVALUATION............................................................................................................17
2.5.1 Annual Site Compliance Evaluation.....................................................................................17
2.5.2 Recordkeeping and Internal Reporting.................................................................................17
2.5.3 Plan Revision........................................................................................................................17
2.6 PLAN REQUIREMENTS.......................................................................................................18
2.6.1 Plan Location and Public Access..........................................................................................18
2.6.2 Plan Required Modifications................................................................................................18
APPENDIX A Site Diagram
APPENDIX B Biweekly Inspection Form
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MANAGEMENT APPROVAL
This BMP/SWPP Plan is a comprehensive plan, prepared in accordance with good engineering
practices, and has the full approval of management at a level with authority to commit the necessary
manpower and equipment resources. This BMP/SWPP Plan will be implemented as described herein.
Signature:
Name: Danny Yu
Title: Director Of Operations
Date:
Page 14

INTRODUCTION
This document is a Storm Water Pollution Prevention Plan prepared for Metallum Recycling. Metallum
Recycling processes and sells scrap metal, salvages and recycles military automotive vehicles and
components, and maintains facility vehicles and equipment. This plan is designed to prevent or
minimize the release of pollutants into storm water runoff from on -site industrial processes. Preparation
and implementation of this Storm Water Pollution Plan is required by the Storm Water Regulations
developed under the federal Clean Water Act (CWA) to control the exposure of storm water to
industrial activities. The plan requires the implementation of "Best Management Practices" (BMPs) to
control the likelihood of storm water contamination. Under Storm Water Regulations, industrial
facilities are required to implement control measures that meet the Best Available Technology/Best
Control Technology (BAT/BCT) standards, rather than specific numerical discharge limitations.
BAT/BCT basically requires the introduction of state-of-the-art pollution control measures.
This Storm Water Pollution Prevention Plan creates a Pollution Prevention Team (PPT) at Metallum
Recycling. This PPT is responsible for the implementation, periodic review, assessment, and revision
of the Plan. The PPT structure spreads responsibilities for environmental planning and compliance to
several areas of the organizational structure.
The team's short-term activities require addressing storm water pollution issues identified during site
assessments of the facility. Control measures are designed to remedy the most pressing threats to storm
water at Metallum Recycling. The team's long term activities include analyzing specific task or
operational areas to determine what activities pose significant threats to storm water, and designing
and implementing measures to ensure pollution prevention and risk minimization.
A site assessment of the facility revealed storm water systems that are fundamentally sound. Storm
water basically flows from the compound via the natural contours of the property with little artificial
infrastructure.
The pollution prevention team, herein established, is responsible for analyzing operational processes,
the movement and storage of non -hazardous materials (raw materials, products, and waste) and the
training of employees at Metallum Recycling in storm water pollution prevention. They are responsible
for assuring that organizational decisions are made with proper consideration of storm water pollution
prevention and risk minimization issues. The team is made up of members chosen from Metallum
Recycling management. It is essential to the success of this Plan that Metallum Recycling dedicates
sufficient resources to the task of addressing environmental problems and implementing effective
solutions.
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1. GENERAL INFORMATION
1.1 Metallum Recycling, LLC
Address: 1459 US-117,
Warsaw, NC 28398
Phone: [phone]
1.2 USGS Coordinates
Latitude: 340 57' 37.23" N
Longitude: -78' 4' 39.73" W
1.3 Emergency Contacts
Primary Contact: Ivan Zhao
Title: Managing Member
Phone: [phone]
Alternate 1: Danny Yu
Title: VP/Director of Operations
Phone: [phone]
1.4 Type of Industry
Metallum Recycling is a scrap metal/automotive parts salvage and recycling yard.
1.5 SIC Codes
Primary: 5093 — Recycling of Scrap Metal
1.6 EPA Hazardous Waste Identification Number
N/A
1.7 Operating Schedule
The schedule of work is 0700 to 1600 Monday through Friday.
1.8 Facility Security
Metallum Recycling has security cameras operating 24/7 at the facility. Additionally, there is a chain
link fence and tree line bordering the entire property.
The team periodically reviews security measures and ensures that adequate safeguards for security (and
thus storm water) are being taken. The team monitors areas of potential pollutant discharge and formal
employee training in spill response and emergency procedures are conducted.
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2. STORM WATER BEST MANAGEMENT PRACTICES (BMP) PLAN
2.1 Organization
This Storm Water Pollution Prevention Plan has been prepared/revised based on periodic site
assessments of Metallum Recycling. The Plan creates a Pollution Prevention Team responsible for the
implementation, periodic review, assessment, and revision of the plan. The team is responsible for both
short-term and long-term activities designed to prevent storm water pollution and encourage sound
environmental management practices at Metallum Recycling.
The team's short-term activities include addressing "best management practices"(BMP) options for
storm water pollution sources identified during periodic site assessments of the facility. The BMP
options are designed to remedy the most pressing threats to storm water. The team's long term activities
include analyzing specific task or operational areas to determine what activities pose significant threats
to storm water. Based on this analysis, the team will design and implement measures to ensure pollution
prevention and risk minimization procedures. Each team member is responsible for training employees
under their task area.
The pollution prevention team has been organized (as much as possible) along current task or
operational lines. This method safeguards organizational continuity and enhances the environmental
protection and pollution prevention structure already established at Metallum Recycling. It is intended
that this effort will further assist Metallum Recycling in environmental management and regulatory
compliance.
2.1.1 Pollution Prevention Team
The Pollution Prevention Team consists of on -site personnel responsible for oversight of important
organizational areas that potentially impact storm water. The team and its leadership are designed to
be the driving force behind the development, implementation, maintenance, and revision of the plan.
Metallum Recycling is a scrap metal/automotive part recycling yard. This Storm Water Pollution
Prevention Plan is designed to focus decision making on environmental issues and to ensure that
organizational tasks are carried out with an eye toward storm water pollution prevention and risk
minimization. For this reason, the team includes members of management. In addition, the plan
encompasses decision making in the area of administrative procedures.
The Pollution Prevention Team is designed to carry out several tasks. First, the Pollution Prevention
Team ensures that BMP options for storm water pollution identified during periodic site evaluations
are addressed and final solutions carried out. The BMP options address the most pressing threats to
storm water at Metallum Recycling. Second, Pollution Prevention Team Members are to conduct
periodic analyses of task areas and discuss/correct actual or potential threats to storm water. Identified
potential threats are used by the Pollution Prevention Team to review storm water management at
Metallum Recycling. Finally, the Pollution Prevention Team periodically reviews, assesses, and
revises the Plan as needed. The Pollution Prevention Team members and their respective duties are
individually addressed on the following pages.
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STORM WATER POLLUTION PREVENTION TEAM
TEAM LEADER: VP/Director of Operations
RESPONSIBILITIES:
The Pollution Prevention Team Leader oversees the management of this Plan and ensures that all
decisions concerning production, operations, materials procurement, finance, and administration are
made with due consideration for storm water pollution prevention and risk management. He shall be
responsible for ensuring that products stored and used on -site minimize environmental hazards and
that any new equipment purchased or used at the site complies with the Best Available
Technology/Best Control Technology (BATBCT) standards. He shall also be accountable for spill
prevention at Metallum Recycling and responsible for setting up the necessary emergency spill
procedures and reporting requirements to isolate, contain, and clean-up spills and emergency releases
before a discharge can occur.
The Team Leader serves as the primary contact for this Plan and is responsible for regulatory
compliance. He shall be responsible for overseeing the completion of controls required by the Plan and
shall ensure that Pollution Prevention Team Members carry out their assigned tasks. He also ensures
that adequate resources are dedicated to this effort. Further, the Team Leader is responsible for ensuring
adequate security at the site and for the periodic review, assessment, and revision of the Plan. He
oversees worker training and compliance efforts and conducts periodic Pollution Prevention Team
review meetings to assess and revise the Plan. The Team Leader is ultimately responsible for the
implementation and success of the Plan.
STORM WATER POLLUTION PREVENTION TEAM
TEAM LEADER, ADDITIONAL DUTIES:
SAFETY AND TRAINING
RESPONSIBILITIES:
The Team Leader is also responsible for overseeing employee training in storm water pollution
prevention, risk minimization, and safety. He shall integrate storm water training requirements with
other health, safety, and hazard communications programs. He shall design training requirements and
ensure the Pollution Prevention Team Members are prepared to train employees under their task areas.
He shall also be responsible for ensuring that hazardous materials are equipped with proper content,
spill response, and emergency contact labels.
The Team Leader shall ensure that the training program is sufficient to verify that employees are fully
aware of storm water pollution prevention, risk minimization, and emergency response procedures. He
shall identify problem areas, sustain current training programs, and implement appropriate suggestions
for better training practices.
The Team Leader shall also be responsible for storm water testing and sampling, sending samples to a
certified laboratory, and receiving the storm water test results. He shall insure the owner certifies the
electronic Discharge Monitoring Report (DMR) and maintains a copy of all monitoring results in the
facility's environmental records. He will identify pollution prevention issues, as well as assist in the
continuous implementation of measures to sustain the Plan.
STORM WATER POLLUTION PREVENTION TEAM
ASSISTANT TEAM LEADER: Managing Member
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RESPONSIBILITIES:
The Assistant Team Leader serves as the primary link between the employees and the Team Leader,
and shall temporarily assume the role of Team Leader should the need arise. The Assistant Team
Leader shall have primary responsibility for coordinating pollution prevention and risk minimization
activities under this Plan. He is responsible for materials procurement, team oversight, materials
storage and labeling, and the periodic review and revision of the Plan. In addition, he coordinates
construction activities; the movement of equipment; waste storage, handling, and disposal; sanitation;
and grounds keeping (including the storm water drainage system) activities. He ensures that activities
under the task areas are assessed for their potential adverse effect on storm water.
The Assistant Team Leader oversees the Team's analyses of areas that pose a threat to storm water.
Analysis shall include problem areas, current pollution prevention and response procedures, and
suggestions for better management practices. The Assistant Team Leader is also responsible for
overseeing employee training in pollution prevention and risk minimization. He shall have
responsibility for Plan oversight, assessment, and review.
The Assistant Team Leader is also responsible for conducting inspections, the receipt and storage of
raw materials (scrap metal, hazardous materials), and the storage and shipment of processed scrap
metal/automotive parts. In analyzing these activities, he must consider "direct" impacts on storm water,
such as runoff from materials storage areas, and ensure that all activities under his task area are assessed
for their potential adverse effect on storm water.
2.1.2 EXISTING ENVIRONMENTAL PLANS
Metallum Recycling is currently responsible for employee health and safety and hazard communication
plans under OSHA. The management of these plans is the primary responsibility of the Team Leader.
One objective of this Storm Water BMP Plan is to serve as a medium to develop a more integrated
approach to environmental management and regulatory compliance.
This Plan is tailored to correspond with the Hazard Communication Program that has been developed
for hazardous materials safety under OSHA. In particular, employee training, hazardous material
content, spill response, and emergency contact labeling will be expanded to cover storm water as well.
All employees participate in monthly safety training. Personnel who comprise the Pollution Prevention
Team established in this Plan will conduct training. Employees must sign an attendance sheet to certify
their presence at the training sessions. In addition, the Pollution Prevention Team prepares records on
the training sessions that are kept for subsequent review and permanent filing.
Employee training for storm water pollution prevention has been added to the current employee
training program. The Storm Water Regulations require annual training in storm water pollution
prevention and risk minimization. In addition, employee orientation training is conducted when an
employee begins work or changes jobs, or when new equipment or procedures are implemented. This
training is coordinated by the Team Leader and conducted by the Pollution Prevention Team.
The Pollution Prevention Team will monitor Safety Data Sheets (SDSs) to ensure that any chemical
compounds which pose an adverse impact on storm water runoff are maintained and used in accordance
with manufacturer's instructions.
The Team Leader is designated as the person responsible for spill prevention in this Plan. Therefore,
the Team Leader is responsible for setting up necessary spill emergency procedures and reporting
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requirements to isolate, contain and clean-up spills and emergency releases before a discharge can
occur.
SDSs for all toxic and hazardous chemicals used at Metallum Recycling are kept in notebooks on site
for easy access.
2.2 SITE ASSESSMENT
Designated Metallum Recycling personnel shall conduct and document periodic site assessments and
evaluations of the facility. If the need arises, Metallum Recycling will utilize local engineering firms
for assistance.
Appendix A is a site diagram that identifies the direction of storm water flow around the facility and
storage areas at the site. The diagram should be referenced in conjunction with any discussion of the
storm water drainage system or potential sources of pollution throughout the Plan.
2.2.1 SITE ANALYSIS AND DESCRIPTION OF EXPOSED MATERIALS
The site diagram (Appendix A) reflects the facility's direction of storm water flow around the yard and
locations of potential pollution sources and risks at the facility.
Outfalls and Drainage Areas
The compound is located on terrain which slopes from east to west and north to south. The majority of
the storm water from the facility drains toward the center of the property and exits the site from the
outfail at the middle -edge corner of the property.
Surface Waters
There are no named surface waters on this compound. The only water that leaves the compound is
storm water draining via the natural slope of the property. The team periodically examines the storm
water drainage system for erosion and sedimentation in storm water runoff.
Liquid Storage Tanks
There is a 250 gallon diesel fuel single -walled aboveground storage tank within a steel secondary
containment. This tank is located at mid -west point of the property. All refueling of onsite equipment
is conducted from this storage tank. A spill kit and fire extinguisher are present and serviceable at all
times.
Equipment and Vehicle Maintenance/Repair
Operator -level equipment maintenance and repairs are generally conducted where the equipment sits.
All maintenance and repairs shall be conducted safely with drip pans and drop cloths, which shall then
be properly disposed. Some equipment servicing is performed indoors within the warehouse, thus
minimizing any "direct" contact with storm water. However, indirect contact, such as disposal of parts
and the tracking of petroleum products is a concern. The team will ensure that all precautions are taken
to minimize indirect contact of contaminants with storm water. The team will also visually inspect all
equipment periodically to prevent breakdowns that could lead to storm water exposure.
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The team will consider other issues related to equipment maintenance and repairs. Floor absorbent
used to soak up oil can be tracked outdoors, thereby coming into contact with storm water. Using oil
absorbent socks rather than floor absorbent can minimize this concern. Used parts shall not be
discarded outdoors after repairs are completed. Parts can emit grease and oil when they are exposed to
storm water runoff. To prevent this kind of discharge, adequate indoor storage space for used parts
shall be provided prior to disposal or recycling. Finally, any maintenance or repairs beyond the
capability of the operator are performed off -site.
It should be noted that there is no discharge of vehicle and equipment wash water since Metailum
Recycling does not wash their vehicles or equipment on site. If in the future, Metallum Recycling does
wish to implement a washing program, the team must devise a system for collecting this water, thus
preventing discharge off of the property. The alternative is to modify the permit to include wash water
discharges and conduct monthly monitoring. This alternative does involve additional effort, time, and
expense. The same precautions noted in equipment maintenance and repairs will be adhered to if minor
vehicle maintenance and repairs do take place on the premises.
Storage Areas
All chemical substances are stored within designated storage areas or within the warehouse. All of
these areas have concrete floors with limited access. Container labels must list contents, warnings, first
aid measures, and spill response. Waste oil/fuel is collected periodically by an off -site vendor for
recycling.
Shipping and Receiving
Metallum Recycling does not accept scrap metal or automotive parts unless they have been drained
and purged prior to receiving. Metal scrap is processed by reduction in size and shape. The scrap is
then consolidated in shipping containers for off -site transfer to scrap metal recycling facilities. As a
best management practice, all personnel are trained in spill prevention, containment, and response
procedures.
2.2.2 MATERIALS INVENTORY
An index of products and materials used and stored at Metallurn Recycling is available in the Master
SDS Book. All toxic or hazardous materials are marked with content, spill response, and emergency
contact labels. Hazardous material handling, storage, and disposal techniques; routine and preventative
maintenance; and good housekeeping measures will be included in employee training under this Plan
to ensure pollution prevention and risk minimization.
2.2.3 PAST SPILLS AND LEAKS IDENTIFICATION
There have been no reportable spills at this site in the past three years.
2.2.4 NON -STORM WATER DISCHARGE IDENTIFICATION
There are no non -storm water discharges to surface waters of the US.
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Metallum Recycling monitors and records all notable storm water concerns. A copy of all records are
kept at the facility.
2.2.6 SITE SUMMARY
Based on the visual inspection of the facility, no pollutant discharge is anticipated. The purpose of this
plan is to identify potential pollution sources and risks and suggest appropriate best management
practices to prevent storm water pollution in the future.
The storm water drainage system is fundamentally sound. Metallum Recycling must continue to work
to emphasize housekeeping and maintenance efforts around the site. Housekeeping efforts are
sustained through an ongoing program of preventive and routine maintenance. All of these efforts
require employee training programs in storm water pollution prevention and risk minimization.
The Pollution Prevention Team plans to address longer -term issues, as needed, to assure a sustained
commitment to storm water management and pollution prevention.
2.3 BMP IDENTIFICATION
Periodic site assessments/evaluations at Metallum Recycling are used to identify potential storm water
pollution concerns. In addition to identifying and correcting environmental concerns, the Plan
identifies some longer-tenn issues. The Pollution Prevention Team is responsible for establishing an
organizational course that incorporates decision -making, operational processes, and employee training
activities toward storm water pollution prevention and risk minimization.
The following is the framework for the Pollution Prevention Team's BMP efforts. Each Pollution
Prevention Team Member will analyze task areas and the associated operational activities within that
task area. This analysis also serves as the basis for future planning and activities under this Plan. The
basic analysis should address the following BMP topics:
- Good Housekeeping
- Preventative Maintenance
- Visual Inspections
- Erosion and Sediment Control
- Management of Runoff
- Employee Training
- Recordkeeping and Reporting
- Specific BMPs for each Organizational Task Area
A discussion of each BMP section is provided below.
2.3.1 GOOD HOUSEKEEPING
Pollution Prevention Team Members emphasize the importance of housekeeping among employees,
including the identification of current practices and potential sources of storm water pollution and
implementing any changes that would prevent storm water pollution and aid risk minimization efforts.
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Storm water pollution prevention requires improving and maintaining housekeeping. Good
housekeeping practices are designed to maintain a clean and orderly work environment in order to
reduce the amount of waste generated and to decrease the chances for storm water contamination. Good
housekeeping includes all phases of Metallum Recycling's operations: the receipt, movement, and
storage of materials (raw materials, products, and waste); operational processes; inventory control and
management; equipment maintenance and repair; and clean-up activities.
Each Pollution Prevention Team Member specifically addresses improvements in housekeeping efforts
in the following areas:
1.Operational and Maintenance Activities
- Are work areas kept clean and dry?
- Is garbage and waste material regularly picked up and discarded properly?
- Are equipment and stored materials routinely inspected for leaks?
- Are spill cleanup procedures understood by employees?
2. Material Storage Practices
- Is an up-to-date inventory kept of all materials (hazardous and non- hazardous)?
- Are all chemical substances present in the workplace identified?
- Are all containers labeled?
- Are all containers kept tightly closed to avoid chemical interaction with air/storm water?
3. Employee Participation in Storm Water Pollution Prevention
- Are employees frequently and properly trained in good housekeeping techniques?
- Is good housekeeping discussed at employee meetings?
- Are employee inputs encouraged and included?
2.3.2 PREVENTATIVE MAINTENANCE
Pollution Prevention Team Members identify and implement preventative maintenance practices
within the work areas that aid storm water pollution prevention and risk minimization efforts.
Preventative maintenance plays a major role in storm water pollution prevention. All equipment must
be inspected for cracks or slow leaks that could cause breakdowns or failures. Such failures have the
potential to result in discharges of chemicals to storm water.
Each Pollution Prevention Team Member's preventative maintenance efforts include the following:
- Identification of equipment, systems, and facility areas that should be inspected
- A schedule for twice a week inspections or tests of the identified equipment and systems
- Appropriate and timely adjustment, repair, or replacement of equipment and systems
- Maintenance of complete records on inspections, equipment, and systems
2.3.3 VISUAL INSPECTIONS
Metalium Recycling has implemented a twice a week visual inspection program for equipment and
structural controls. Visual inspection programs supplement normal preventative maintenance efforts
and are particularly important for production, shipping and receiving, and equipment maintenance
areas. Visual inspections are essential for the early detection of malfunctioning structural controls,
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leaking equipment, oil spills, and housekeeping lapses. A written log is maintained to document the
inspections, identify problems, and initiate associated corrective actions.
The written log identifies the visual inspection activities to be performed. The log is kept in either a
calendar or in a simple checklist form. Appendix B contains a sample form. Each entry is initialed by
the Pollution Prevention Team Member who performed the inspection. The log is periodically
reviewed by the Pollution Prevention Team Leader and placed as a permanent record with this Plan.
2.3.4 SPILL PREVENTION AND RESPONSE
Spill prevention and response procedures are absolutely critical to effective storm water pollution
prevention and risk minimization efforts. Pollution Prevention Team Members will identify spill
prevention procedures currently in place and make suggestions for improving the quality and
effectiveness of these procedures. It is vitally important that all substances are properly labeled and
that emergency procedures and contact personnel are designated on the labels. Additionally, areas
where spills are most likely to occur on -site and their drainage points should be identified and included
in training and BMP management.
Spill/fire prevention and response procedures are posted in all hazardous material storage areas. in
addition, the Assistant Team Leader will maintain records of all spills and response activities. A master
copy of the spill prevention and response procedures and records of any spills will be kept with this
Plan.
Metallum Recycling ensures that adequate equipment is procured and stored on -site for personnel to
effectively respond to a spill emergency. The storage locations for this equipment are clearly marked,
and all employees receive training in emergency equipment storage and use. The equipment is stored
in strategic locations at the site to ensure it will be easily accessible in an emergency.
2.3.5 EROSION AND SEDIMENT CONTROL
Erosion and sedimentation are a major concern at Metallum Recycling, as much of the property is
unvegetated, ungraded, or not paved. Sediment control is primarily a housekeeping issue that requires
proper clean up and maintenance activities.
Pollution Prevention Team Members identify signs of erosion and sedimentation, and note any areas
where excessive litter, debris, soil, or other foreign objects are exposed to the storm water drainage
system. The Pollution Prevention Team strives to implement proper techniques to ensure erosion and
sediment control, to include silt fencing, hay bales, hydroseeding, or gravel/rock stabilization. The
Pollution Prevention Team also ensures that litter and debris around the property are continuously
cleaned up and properly discarded.
2.3.6 MANAGEMENT OF RUNOFF
Management of runoff is a concern at Metallum Recycling, because the storm water naturally drains
off the property to the drainage ditch. The Pollution Prevention Team monitors the storm drainage
system to ensure that it is properly maintained and that good housekeeping practices are observed. This
is a primary responsibility of the Assistant Team Leader.
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Pollution Prevention Team Members inspect the runoff areas twice a week and document the condition
of the areas. It is important to inspect the system during a rain event to identify problem areas, such as
system backups, flooding of areas, or the presence of a visible sheen on storm water. The Pollution
Prevention Team considers any structural changes or additions to the storm water drainage system as
part of the annual revision of the Plan.
2.3.7 EMPLOYEE TRAINING
Metallum Recycling currently has an employee training program for all employees. Training covers
employee health, safety and hazard communications. Storm water pollution prevention and risk
minimization is also a separate training topic. Training shall include each of the best management
subjects covered above and will be comprehensive.
Team Members will identify any additional storm water training required and revise training programs
as appropriate. Records of all BMP training programs are submitted to the Assistant Team Leader and
retained with the Plan.
2.3.8 RECORDKEEPING AND REPORTING
Each Pollution Prevention Team Member is responsible for records of all activities undertaken to
enhance storm water pollution prevention and risk minimization. In addition, any significant spill, leak,
or accident that occurs is brought to the immediate attention of the Team Leader responsible for
overseeing any required remediation actions and placing a permanent description of the event with the
Plan.
The records should address any changes or additions to the BMP areas discussed above: Good
Housekeeping; Preventative Maintenance; Visual Inspections; Spill Prevention and Response; Erosion
and Sediment Control; Management of Runoff; and Employee Training. The information is submitted
to the Pollution Prevention Team Leader and is discussed at Pollution Prevention Team meetings. The
information will also serve as the basis for this Plan's annual review, assessment, evaluation, and
revision. A master copy of all activities undertaken to enhance pollution prevention and risk
minimization efforts is kept with this Plan as a permanent record of the Teams activities.
2.3.9 ADVANCED BEST MANAGEMENT PRACTICES
In addition to the BMPs that are incorporated into the day-to-day operations, the Pollution Prevention
Team is responsible for identifying and implementing what are termed "advanced" BMPs. "Advanced"
BMPs are significant practices or equipment that enhance pollution prevention and risk minimization
efforts. "Advanced" BMPs are developed based on an analysis of significant impacts to storm water
runoff and should be included as part of the Plan; however, as "advanced" BMPs may require capital
expenditures, it is appropriate that the P2 Team Leader is ultimately responsible for their identification
and implementation.
Storm Water Regulations require that facilities employ the "Best Available Technology (BAT)
Economically Achievable" to reduce pollutant discharges. This standard should guide future
managerial decision -making at Metallum Recycling, even though achieving BAT may require capital
outlays such as the purchase of new energy efficient or low polluting equipment. In considering
"advanced" BMPs and achieving BAT, the Team Leader should consider the following factors:
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- The age of equipment and the facility
- The process employed
- The engineering aspects of the application of various types of control techniques
- Process changes
- The cost of achieving effluent reduction
- Non -water quality environmental impact (including energy requirements)
2.4 PLAN IMPLEMENTATION
This Plan initiates measures that are designed to provide the framework under which the Pollution
Prevention Team operates. The Pollution Prevention Team is responsible for both short-term and long-
term activities designed to prevent storm water pollution and encourage sound environmental
management.
The Pollution Prevention Team's short-term activities require addressing storm water pollution
concerns identified during the periodic site assessments of the facility. BMP options are control
measures designed to remedy the most pressing threats to storm water. The Pollution Prevention
Team's long-term activities include analyzing specific task or operational areas to determine what
activities pose significant threats to storm water, and to design and implement measures to ensure
pollution prevention and risk minimization.
Pollution Prevention Team meetings are held at least annually and may be separate meetings or
scheduled to coincide with other organizational activities. It is sometimes easier for the Pollution
Prevention Team to meet immediately following other employee safety/training meetings. These
meetings provide a ready forum and assure that all personnel can attend.
2.4.1 APPROPRIATE CONTROLS
The Pollution Prevention Team provides guidance for addressing the elements of a BMP Plan.
The Pollution Prevention Team should address the following issues:
- Inspect any areas around the facility that are visibly stained with oil, grease, or hydraulic fluid, and
clean these areas as necessary.
- Integrate labeling requirements under OSHA with material content, spill response, and emergency
contact labels required by the storm water regulations. Ensure that all materials are properly labeled.
- Expand the scope of monthly employee safety and training meetings to include storm water
pollution prevention and risk minimization.
- Segregate stored materials according to content, i.e. corrosives in one area, flammables in another.
In addition to these immediate efforts, the Pollution Prevention Team must develop or sustain a longer -
term strategy to address the following issues:
- Design, implement, and enforce an effective good housekeeping policy for the entire facility
- Oversee the implementation of a comprehensive employee training program for pollution
prevention
- Review material storage to verify the implementation of pollution prevention measures and risk
minimization techniques
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2.4.2 EMPLOYEE TRAINING
In addition to the normal employee -training program for storm water pollution prevention and risk
minimization, specific "advanced" training shall be provided for storm water pollution controls. This
"advanced" training will be targeted at responsible personnel within the pollution prevention hierarchy.
Metailum Recycling will also consider formal training and specialized storm water seminars for key
personnel. "Advanced" training may also be appropriate for Pollution Prevention Team Members who
have responsibilities under this Plan.
The Storm Water regulations require an annual BMP evaluation, review, and potential revision by the
Pollution Prevention Team. The Pollution Prevention Team shall conduct an annual site compliance
evaluation, a review of recordkeeping and reporting activities, and a comprehensive review and
revision of the Plan.
It is essential that the Pollution Prevention Team determine which BMPs from the previous year have
been met, which have not, and why not. Only through this process can new BMPs be established for
the coming year. The Pollution Prevention Team must also establish clear criteria to confirm what
constitutes the successful completion of given actions or tasks.
2.51 ANNUAL SITE COMPLIANCE EVALUATION
The annual site review of the facility will include:
- An inspection of the storm water drainage system for evidence of pollutants entering the drainage
system
- Observation of structural measures, sediment controls, and other storm water management controls
and an evaluation of whether additional measures are needed
- Documentation of the annual evaluation addressing whether the controls identified in the Plan have
been implemented and suggestions on what the Pollution Prevention Team might include in its
annual Plan revision
2.5.2 RECORDKEEPING AND INTERNAL REPORTING
The Pollution Prevention Team Leader shall document Pollution Prevention Team Meetings and all
reports required under the Plan. He shall also ensure adequate resources are provided for this effort.
The records shall cover the annual site compliance evaluation, a review of recordkeeping and reporting
activities, and the comprehensive review and revision of the Plan.
2.5.3 PLAN REVISION
The Plan shall be assessed and revised by the Pollution Prevention Team as needed to ensure pollution
prevention and risk minimization. The Pollution Prevention Team will develop a revised Plan, or
document that no revisions are necessary, annually. Each Pollution Prevention Team Member shall
review the plan and identify new BMPs to be implemented. The revision will be prepared under the
direction of the Pollution Prevention Team Leader.
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2.6 PLAN REQUIREMENTS
Following are the chronological and legal requirements that Metallum Recycling must implement.
2.6.1 PLAN LOCATION AND PUBLIC ACCESS
A copy of the Plan and subsequent revisions shall be kept on file at the office of the Team Leader.
Public access shall be in accordance with standard Metallum Recycling procedures and applicable law.
2.6.2 REQUIRED PLAN MODIFICATIONS
If the permitting authority requires any changes to this document, they shall be made within 30 days
of notification, unless otherwise provided by the notification. If changes are required, Metallum
Recycling must submit a signed certification attesting that the changes have been made.
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Appendix i>
Biweekly Inspection1
Metallum Recycling
Biweekly Inspection Form
N
Description & Comments
Y*
Stora a tanks
Tank surfaces show signs of leakage
Tanks are damaged, rusted or deteriorated
Bolts, rivets, or searns are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
Secondary containment is damaged or stained
Waterlproduct in interstice of double -walled tank
Tank fill ports are open or not locked
Piping
Valve seals, gaskets, or other appurtenances are leaking
Pipelines or supports are damaged or deteriorated
Joints, valves and other appurtenances are leaking
Buried piping is exposed
Storage Yard
Materials Stored Properly
Hydraulic Lines OK?
Soil Stained?
Poor Housekeeping?
Outfall
Outfall Clear of Debris and Sediment
Out all Clear of Visible Sheen
Erosion evident?
Vegetation Discolored
Security
Fencing, gates, or lighting is non-functional
Response Equipment
Response equipment inventory is not complete
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