NCG200506_NOV Response_20190508

On March 28, 2019 JMB Recycling and Demolition, LLC. was inspected by Isaiah Reed of the
North Carolina Department of Environmental Quality. On said day Mr. Reed observed the following; 1.
"the adjacent land is now being used for vehicle storage", and 2. "material handling practices in the
vehicle draining area have resulted in spills of oil and other waste material". In response to such actions
JMB Recycling and Demolition, LLC. has responded and modified its procedures as followed.
1.) The adjacent land that is used for parking, and up till said day had been used for access scraped
vehicles that had not been drained, has been updated into the facility's Stormwater Pollution
Prevention Plan and is provided in these documents and the contaminated soil is being removed
and is being sent to the proper facility for handling
2.) The preventative maintenance, housekeeping, and material handling practices in the vehicle
draining area that resulted in the spilling of oil and other waste material was a result of
improper handling by an operator that did not follow procedure and protocol that was outlined
in the old JMB Recycling handbook. In response JMB has made the following changes to our
handbook and procedures as well as our employee training.
In the event of a spill in the immediate vicinity of the facility, the company should assume that its
products and facilities are involved in the spill/leak event until satisfied otherwise.
Operations and Maintenance Procedures
All oil unloaded at JMB Recycling and Demolition, LLC. should be handled in the safest manner
according to applicable regulations. JMB Recycling and Demolition, LLC. should ensure that the draining
of these products entering the facility property are responsibly training their employees in safe handling
practices.
Spills or leaks that may occur should be contained as quickly as possible by use of a sorbent material.
Facility managers and personnel should ensure that existing tanks be contained in such way that any
leaks or discharges from vehicles/equipment are retained on sire long enough for cleanup to occur. For
draining of vehicles on the unloading rack, a fixed containment will be provided for the single largest
compartment of any storage tank or vehicle handled at this location. Contained oil from a spill event
would be disposed by a licensed waste contractor.
JMB Recycling and Demolition, LLC. prevention measures in the vehicle processing are
1) Store absorbent materials near equipment
2) Implement regular maintenance schedule to inspect and replace any material that may be
deemed faulty
3) Inspect equipment daily for leaks deceived
4) Provide secondary containment
5) Construct roof over equipment
6) Place barriers around equipment to protect from traffic MAY - 8 2019
Land Quality Section
A,hcville

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Spill Notification Procedures
In the event of a release of material any employee observing a spill of oil, fuel, gasoline or related
material of any quantity will immediately:
• Initiate containment/cleanup if safe to do so
• Contact facility agent or general manager or acting representative
• Report the following information:
1. Location of spill;
2. Type of material spilled (fuel, oil, gasoline) — provide chemical name;
3. Estimated volume of spill;
4. Fate of spilled substances- is substance contained or is it moving toward drainage ditch or
storm drain system;
5. Action taken to contain and clean up;
6. Is outside assistance needed for control or clean up;
7. Estimated quantity of material entering surface waters;
8. Surface waters affected or threatened by material;
9. Time, date and duration of spill;
10. Weather conditions;
11. Name of person reporting spill.
Spill Response Procedures
A spill of solvents, gasoline, process oils, or any other oil products spill should not be allowed to
remain on the property owned by JMB Recycling and Demolition, LLC. Any suspected release of oil will
be met with the response procedures provided in this SPCC Plan.
The first person on the contact/responsible parties list should be located in the event of a
suspect spill/leak to determine the severity of the spill and to begin appropriate spill control and clean-
up procedures. All detected spills and/or leaks should be considered the responsibility of JMB Recycling
and Demolition, LLC. unless the material comprising the spill is identified as belonging to another
owner/operator.
Any suspect spill and/or leak source(s) on the JMB Recycling facility should be thoroughly investigated.
The following determination be made during the search for spills or leaks:
• Have there been any spills during loading or unloading of petroleum products?
• Are any storage tanks, vessels, drums leaking or have they been leaking?
• Has there been any maintenance performed on tanks, vessels, piping or other equipment that
could have resulted in a release?
0 Have there been any odors or other indications of liquid in unusual areas?

Spill Control and Containment
The following equipment should be available at JMB Recycling and Demolition, I.I.C. facility:
• Granular Absorbent Materials for spill cleanup on the yard
• Absorbent pads for spill cleanup on the yard
• Absorbent booms for spill containment on the yard
• Hand tools for spill cleanup and containment on yard and service trucks
• Drums or large containers for spill cleanup on the yard
• Fire extinguishers for fire suppression on the yard/ operating equipment/ all facility buildings
Any additional required actions involve the following:
• Spillways are to be blocked to inhibit the spill from entering runoff waters by using the
equipment listed above;
• Dirt, straw fencing, and sorbent-built filter dams should be utilized to control the movement of
the spill;
• Materials that cause oil to sink or disperse will be avoided;
• Oil, oil -soaked sorbent, straw, and soil should be placed in metal, leak tight drums and labeled
properly;
• If the oil can be properly controlled and diverted to an oil separator system
Clean-up Procedures
JMB Recycling and Demolition, LLC. has various spill cleanup and containment supplies strategically
located throughout the facility. Any spills on -site should be clean up by JMB Recycling employees. Small
spills will be covered immediately with granular absorbent material to contain the spill. After the spill
has been covered, the spill substance/granular absorbent material should be swept/shoveled till the
material is absorbed into the granular material. The mixture is to be picked up and disposed of in a roll
off container. This method of cleaning will be repeated as many times as necessary to completely clean
up any visible liquid. After all of the liquid has been removed, a light coat of granular absorbent material
is to be left on the affected area. The spill area should be checked on the hour to observe for any
additional liquid absorption.
Spill material in any on -site containment areas should be recovered from the area as soon as possible to
prevent the release of spill product. Any contaminated soils will be removed and disposed of in
accordance with applicable regulatory requirements. Major oil spills that are likely to enter the nearest
body of water will require the assistance of a clean-up contractor.

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Personnel Training
Each facility regulated under the SPCC regulations should have a designated person responsible
for oil prevention and who reports directly to management. All managerial and supervisory personnel
who may have oversight responsibilities should be thoroughly familiar with the contents of this SPCC
Plan.
All employees should be familiar with the requirements relative to the reporting all spills; the
contingency plan of the scrap yard; and, the materials available for the control and clean-up of spills.
A meeting of the managerial and supervisory personnel to discuss the SPCC Plan should be held when a
new or revised SPCC Plan is received. To keep spill prevention a high priority issue, meetings should be
held at regular intervals to update the plan. At least annually, all personnel directly involved in the
facility operations should be instructed on the preventive measurers that have been taken to prevent
spillage into nearby waterways and a demonstration should be made relative to the use of all spill
containment equipment. These training sessions should include a thorough review of the plan including
corrective actions to be taken in the event of a spill and the appropriate contacts to be made. The
training program should include (but not limited to):
• Emergency response operations;
• Communication procedures;
• The location of all storage areas for oil products;
• Health and safety issues;
• Containment and clean-up procedures for spillage;
• Reporting;
• Required follow-up activities;
• Any known spills events or failures;
• Malfunctioning components
New employees should be thoroughly instructed by their supervisors, upon employment, with respect
to spill prevention procedures and the SPCC Plan. Emphasis should be given to reporting requirements,
contingency plan, and available materials for control and clean-up of spills.
Annual training is recommended for appropriate personnel with respect to the performance of
equipment inspection, use of spill containment and clean-up equipment, and completion of the
appropriate records properly.
A record of those personnel attending all training sessions should be kept with the SPCC Plan and
records or with company training records.
Security
All of the scrap yards handling, processing, and storing areas should be fully fenced and
entrance gates and should be locked and/or guarded when the facility is not in production or is
unattended.

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