STORMWATER POLLUTION PREVENTION PLAN (SWPPP) For Industrial Activity. National Pollution Discharge Elimination System General Permit # ARR000000

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3 STORMWATER POLLUTION PREVENTION PLAN (SWPPP) For Industrial Activity National Pollution Discharge Elimination System General Permit # ARR Permit Tracking Number: To Be Assigned Prepared for: M&M Metal Recycling, Inc Heber Springs Road Drasco, Arkansas (870) Industrial Sector: N-1 (Scrap Recycling & Waste Recycling Facilities except Source-Separated Recycling); SIC Code: 5093 Prepared by: SWPPP Preparation Date: July 20, 2012

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5 TABLE OF CONTENTS GENERAL FACILITY INFORMATION OVERVIEW Introduction SWPPP Content STORMWATER POLLUTION PREVENTION TEAM FACILITY DESCRIPTION Facility Location Site Activities Site Description Facility Process and Storage Areas Storm Water Drainage System IDENTIFICATION OF POTENTIAL STORMWATER CONTAMINANTS Historic Spill and Leak Record Potential Areas for Storm water Contamination Significant Material Inventory A Summary of Available Storm Water Sampling Data INVENTORY OF EXPOSED MATERIALS Non-Storm Water Discharges STORMWATER MANAGEMENT CONTROLS Best Management Practices Preventative Maintenance Good Housekeeping Spills and Leaks/Prevention Spill Control Equipment Container Management and Storage Labels Source Area Controls Erosion Control Measures Diversions... 20

6 6.2 Employee Training EVALUATIONS AND INSPECTIONS Quarterly Visual Site Inspections Annual Comprehensive Site Compliance Evaluation Bi-Annual Sampling and Analyses Sampling Procedures Natural Background Pollutant Level Annual Update of the SWPPP COMPLIANCE AND REPORTING REQUIREMENTS Employee Training Implementation Schedule Record and Reporting Requirements Records Records Contents Reporting Provisions for Amendment of the Plan SWPPP Availability CERTIFICATION OF THE SWPPP... 32

7 Stormwater Pollution Prevention Plan GENERAL FACILITY INFORMATION Name of Facility: M&M Metal Recycling, Inc. Facility Address: 6159 Heber Springs Rd., Drasco, AR Facility Contact: Name: Matt Stiles Title: Facility Owner and Operator Mailing Address: 6159 Heber Springs Rd., Drasco, AR Telephone: Fax: Standard Industrial classification (SIC) Code: 5093 Permit Information: Facility Permit Name: M&M Metal Recycling, Inc. Permit Number: To Be Determined Initial Date of Coverage: To Be Determined Number of Storm Water Outfalls: 1 Receiving Waters: A drainage ditch to unnamed tributaries, then Peter Creek. Emergency Contact (preferably on-site): Name: Matt Stiles Telephone: Fire Extinguisher Location: In main office building and storage warehouses. Fire Department Phone Dial 911 Spill Control Materials and Locations: In storage warehouses. Spill Reporting and

8 Stormwater Pollution Prevention Plan 1.0 OVERVIEW 1.1 Introduction The primary goal of the storm water permit program is to improve the quality of surface waters by reducing the amount of pollutants potentially contained in the storm water runoff. Industrial facilities subject to industrial storm water National Pollution Discharge Elimination System (NPDES) General Permit #ARR must prepare and implement a SWPPP for their facility. This SWPPP describes this facility and its operations, identifies potential sources of storm water pollution at the facility, recommends appropriate best management practices (BMPs) or pollution control measures to reduce the discharge of pollutants in storm water runoff, and provides for periodic review of this SWPPP. Development, implementation, and maintenance of the SWPPP will provide M&M Metal Recycling, Inc. with the tools to reduce pollutants contained in storm water discharges and comply with the requirements of the storm water permit issued by the State of Arkansas. The primary goals of the SWPPP will be to: Identify potential sources of pollutants that affect storm water discharges from the site; Describe the practices that will be implemented to prevent or control the release of pollutants in storm water discharges; and Create an implementation schedule to ensure that the practices described in this SWPPP are in fact implemented and to evaluate the plan s effectiveness in reducing the pollutant levels in storm water discharges. 2

9 Stormwater Pollution Prevention Plan 1.2 SWPPP Content This SWPPP includes all of the following: Identification of the SWPPP coordinator with a description of this person s duties; Identification of the SWPPP implementation team members; Description of the facility including information regarding the facility s location and activities as well as a site description and a summary of the storm water drainage system; Identification of potential storm water contaminants; Description of storm water management controls and various BMPs necessary to reduce pollutants in storm water discharge; Description of the facility monitoring plan; and a Description of the implementation schedule and provisions for amendment of the plan. 2.0 STORMWATER POLLUTION PREVENTION TEAM All employees of M&M Metal Recycling, Inc. are responsible for continuously observing, reporting and initiating corrective actions when conditions require them. The Storm Water Pollution Prevention Team will be composed of at least two members from the facility personnel. Additional members will be added as necessary to assure that all elements of the SWPPP are fully implemented. The team will have the responsibility of overseeing the facility s storm water management program and coordinating this program with other regulated programs at the facility. It will be 3

10 Stormwater Pollution Prevention Plan the primary task of this team to implement, maintain, and revise, as necessary, the facility s SWPPP. The Team Leader for the facility will be Mr. Matt Stiles. Mr. Stiles serves as Facility Manager and has the responsibility for environmental affairs and operational activities at the facility. Mr. Stiles will be the coordinator for training and implementation of the SWPPP and will coordinate with the Arkansas Department of Environmental Quality (ADEQ) as necessary. Mr. Jimmy Pedigo will serve as the day-to-day Team Coordinator of storm water activities and will ensure that all inspections and reporting are completed within allotted time frames. Specific task assignments will be made by the Team Leader. Basic responsibilities of the team will include, but will not be limited to, the following: Coordination of all stages of plan development and implementation; Coordination of an employee training program; Recordkeeping; Preparation and timely submittal of required reports; Performing inspections; BMP identification and implementation; Identifying and incorporating into the SWPPP any process changes; Implementation of the preventative maintenance program; Spill response coordination; Housekeeping responsibilities coordination; and Selection of storm water management options. SWPPP responsibilities are assigned to each member of the team. When revisions are made, the SWPPP will also be revised and updated. Likewise, when a member of the team is changed, or as new members are added to increase the total size of the team, the SWPPP will be revised. Additional responsibilities may be added to these lists as the need arises. Where those additions are permanent responsibilities, the SWPPP will also be amended to reflect these additional assignments. Table 1 presents the current team for the facility. 4

11 Stormwater Pollution Prevention Plan Team Member TABLE 1 STORMWATER POLLUTION PREVENTION TEAM Primary Responsibilities Phone Number Emergency Number Matt Stiles Team Leader; Signatory Authority BMP Implementation Routine Visual and Quarterly Inspections Sample Collection Employee Training Annual Compliance Review Jimmy Pedigo BMP Implementation Sample Collection Visual Wet Weather Observations Spill Response Housekeeping Recordkeeping FACILITY DESCRIPTION 3.1 Facility Location This SWPPP covers the operations at M&M Metal Recycling, Inc. located at 6159 Heber Springs Rd. in Drasco, Arkansas (see Figure 1 of Appendix A). The site occupies approximately 4.85 acres within Township 11 North, Range 9 West, and Section 3. The facility entrance is located at the following coordinates. Facility Latitude: N Facility Longitude: W M&M Metal Recycling, Inc. is located in the Little Red watershed, which lies within the Arkansas River Basin in North Central Arkansas. The hydrologic unit code for this watershed 5

12 Stormwater Pollution Prevention Plan is There is no upstream watershed. The Lower White-Bayou Des Arc ( ) is downstream. Storm water from the facility discharges into an intermittent drainage ditch at the southeast corner of the site along Heber Springs Road. This ditch drains to unnamed tributaries that flow to Peter Creek, which is not identified on the most recent (2008) 303(d) list of impaired waters, nor does it have a required total maximum daily load (TMDL). Peter Creek drains to Greers Ferry Lake, which is approximately seven miles southwest of the site. The Ultimate Receiving Water for the facility is the White River. 3.2 Site Activities The M&M Metal Recycling, Inc. facility consists of a pre-drained automobile storage area; an automobile crushing area; a ferrous and non-ferrous scrap metal pile (awaiting cutting and/or sorting); a storage bin area for tin, iron, and non-ferrous scrap metals; a loading dock; a propane torch cutting area; scales; two storage warehouses, and an office. Based on site activities, M&M Metal Recycling, Inc. falls under the N-1 (Scrap Recycling and Waste Recycling Facilities except Source-Separated Recycling); Standard Industrial Classification code of Typically, the facility operates eight hours per day, six days per week. 3.3 Site Description The total area of the site is approximately 4.85 acres, and approximately 1.0 acre, or 2 percent, is impervious (i.e., structures). The remainder of the site consists of an approximate 0.85-acre automobile storage area, approximately 1.5 acre of scrap yard (scrap metal storage bin area), plus approximately 1.5 acre of compacted graveled land. Figure 2 of Appendix A is a facility layout map showing the major site features and the location of the storm water outfall. 6

13 Stormwater Pollution Prevention Plan Facility Process and Storage Areas Loading Dock: Scrap recyclable materials are loaded and unloaded using heavy equipment. The first step in any metal scrap recycling operation is getting the metal scrap to the recycling operation and collecting or sorting materials to be processed. Ferrous and Non-Ferrous Bin Storage: Ferrous and non-ferrous scrap metal (not containing iron) is stored in bins according to specific categories (e.g., copper, aluminum, brass scrap). Located near the center of the site. Ferrous and Non-Ferrous Metal Scrap Pile: Large pieces of ferrous and non-ferrous scrap metal are temporarily stored over compacted gravel awaiting sorting and/or cutting. Located at the west central portion of the site. Propane Torch Cutting Area: Hired contractors use their propane torches on a trailer to break apart large metal pieces. Scales: Digital scales for weighing recycling products. Located near the center of the site. Pre-drained Automobile Storage: Approximately uncrushed automobiles (with fluids drained prior to arrival at the site) are stored near the southwest portion of the site until an offsite facility arrives to dismantle and crush them on a trailer, at which point they are removed from the site. Office Building and Storage Buildings (2): The office and one storage warehouse are located near the center of the site. Another storage building is located near the northwest corner of the site. 3.4 Storm Water Drainage System The topography at the site is generally flat, and storm water runoff consists of surface flow that exits the site near the southeast corner along Heber Springs Road. For the purpose of surface 7

14 Stormwater Pollution Prevention Plan water runoff monitoring, one sampling location was identified as a potential high-water outfall. The outfall is identified as discharge point 001. A background sampling location indicative of storm water runoff that may enter the site has been identified as point BG. Figure 2 of Appendix A provides a site map that incorporates facility structures, roads, surface water flow direction, the identified outfall and the background sampling location. This map provides the basis for the SWPPP and will continue to be updated as needed to keep the plan current. 4.0 IDENTIFICATION OF POTENTIAL STORMWATER CONTAMINANTS This section identifies significant materials located at the facility that may potentially contaminate storm water. Additionally, the section presents a record of past spills and leaks, identifies potential areas for storm water contamination, and summarizes available storm water sampling data. 4.1 Historic Spill and Leak Record There are no records or reports of any historic spills at the facility. 4.2 Potential Areas for Storm water Contamination The following potential source areas of storm water contamination were identified and evaluated: Automobile storage area:. Automobile fluids residue from the pre-drained vehicles may be transferred by water to the gravel surface and can potentially contaminate storm water runoff. These contaminants may contain oil and grease, heavy metals, mineral oil, and alcohols. Large uncut scrap storage area: Storm water from this area can be potentially contaminated by rusting steel and residual oil and grease remaining on parts. These contaminants may contain iron oxides, solids, and oil and grease. 8

15 Stormwater Pollution Prevention Plan Driving areas and loading dock: Storm water from these areas can be potentially contaminated by leaking fluids from vehicles parked in the gravel drives and accidental spills during the filling of heavy equipment or facility vehicles. These contaminants may contain oil and grease, mineral oil, and solids. Propane Torch Cutting Area: Storm water from this area can potentially carry away fugitive heavy metal fragments/fines. 4.3 Significant Material Inventory Materials used by the facility that have the potential to be present in storm water runoff are listed in Table 3. This table includes information regarding material type, chemical and physical description, and the specific regulated storm water pollutants associated with each material. TABLE 3 SIGNIFICANT MATERIALS POTENTIALLY AT M&M METAL RECYCLING, INC. Trade Name Material Chemical/Physical Description (1) Storm Water Pollutants (1) Hydraulic oil/fluids Brown oily petroleum hydrocarbon Oil & grease, mineral oil Rust Reddish solid Iron oxides Scrap metal/metal fines Diesel Fuel Metal particulates Clear, blue-green to yellow liquid Metals, biochemical oxygen demand (BOD), total suspended solids (TSS) Petroleum hydrocarbons, oil & grease Table 4 identifies the potential storm water contamination points at the facility. 9

16 Stormwater Pollution Prevention Plan TABLE 4 LOCATIONS OF POTENTIAL SOURCES OF STORMWATER CONTAMINATION Potential Storm Water Contamination Point Potential Pollutant Potential Problem Automobile Storage and Propane Torch Cutting Areas Loading Dock, Scrap Metal Storage Areas Roof Drains from the Onsite Structures and Drive Areas Metals, BOD, TSS, oil and grease, iron oxides Metals, BOD, TSS, oil and grease, iron oxides Oil and grease, petroleum hydrocarbons, mineral oil, BOD, TSS Iron oxide generated from rusting metal parts in scrap yard will discolor storm water and add particulates. Residual oil and grease in steering systems, wheel bearings, etc., may affect storm water. TSS, BOD. Iron oxide generated from rusting metal parts in scrap yard may discolor storm water and add particulates. Residual oil and grease, TSS, BOD. Accidental release of liquids while loading containers of used fluid into shipping trailers. Leaking motor oil from employee vehicles in the parking areas. TSS, BOD. 4.4 A Summary of Available Storm Water Sampling Data M&M Metal Recycling, Inc. has no available sampling data because sampling has not been conducted at the site to date. 5.0 INVENTORY OF EXPOSED MATERIALS M&M Metal Recycling, Inc. stores material in designated areas to minimize mixing of waste streams. Uncontained materials stored outside are as indicated: A 500-gallon mobile diesel fuel tank on a trailer or truck bed Automobile Storage Area Heavy Equipment Propane Torch Cutting Area 10

17 Stormwater Pollution Prevention Plan Uncut Scrap Storage Area Mobile Diesel Fuel Tank One 500-gallon mobile diesel fuel tank is used at the site to fill up heavy machinery. The tank is kept on a trailer or the back of a truck unless empty, then it is stored in the warehouse. All filling activities are closely monitored to prevent overfilling and/or spills. The tank is routinely inspected for integrity and leaks. Areas of significant soil erosion Much of the facility surface is compacted gravel and utilized for driveways, parking and storage. Where transportation routes are not covered with gravel or crushed stone, exposed soils are vulnerable to erosion. These routes could also contribute to elevated TSS levels of storm water discharges. Table 5 presents potential pollutants by operational area and source. 11

18 TABLE 5 POTENTIAL POLLUTANTS BY AREA Significant Areas of The Facility Exposed Materials Or Potential Sources Potential Storm Water Pollutants Qty. Exposed (Approx.) Methods Used to Store/Handle/Process Risk of Release Equipment Fuel Storage Mobile storage tank Diesel gal. tank. Facility heavy equipment vehicles are fueled using a mobile fuel tank stored on a trailer or truck bed. Moderate Outside (Uncovered) Scrap Storage Area Ferrous and nonferrous metal scrap. Metals Extensive, awaiting cutting, sorting, and bin storage. Uncut Large Metal Scrap Stored on compacted gravel. Low Inside (or Covered) Storage Areas Cut and sorted metal scrap. Spent Batteries, Hydraulic Oil Metals, acid, oil and grease Sorted, cut scrap metal in bins with cover; 1-2 pallets stacked 4 batteries high; 5-gallon buckets of hydraulic oil as needed for machinery operation. Cut and sorted metal scrap Storage bins, overflow inside storage warehouse. Batteries - Inside building on pallets. Hydraulic oil In labeled, closed 5-gallon buckets for use as needed. Low Automobile Storage Area Stored, predrained automobiles Storm water from this area can be contaminated by rusting steel and residual oil and grease on parts. May contain iron oxides, solids, metals, and residual oil and grease pre-drained, uncrushed vehicles. Vehicles inspected for fluids prior to acceptance and placement for storage. An offsite facility/purchaser comes to the facility to crush the vehicles on a trailer. The vehicles are then removed from the site. Moderate Propane Torch Cutting Area Fugitive metal fines Metals Limited, as needed An offsite contractor comes to the facility as needed to cut metal scrap; performed on a trailer and fines are collected and removed. Low Scales/Parking Lot/Loading Dock Heavy equipment and facility vehicle fluids Storm water from these areas can be contaminated by leaking fluids from employee vehicles and accidental spills. May contain oil and grease and solids. Limited during conveyance Materials are inspected to ensure hazardous waste removal and/or uncrushed vehicle drainage prior to acceptance and then categorized for crushing, cutting, and/or storage. Moderate 12

19 No process water is used during any stage of operations at the facility. The facility does not produce any hazardous materials either as a finished product or by-product of the recycling operations. M&M Metal Recycling, Inc. has implemented BMPs as shown in Section 6.0, thereby minimizing exposure or impact of potential pollutant sources to storm water. 5.1 Non-Storm Water Discharges M&M Metal Recycling, Inc. has not had a reportable non-storm water discharge. If the event of a non-storm water discharge were to occur, M&M Metal Recycling, Inc. management is aware of the reporting procedures and such event would be documented and proper authorities notified. 6.0 STORMWATER MANAGEMENT CONTROLS This section discusses the storm water management controls required by the permit and describes the management practices selected to address the areas of concern identified in Section 4 of this SWPPP. 6.1 Best Management Practices M&M Metal Recycling, Inc., through the implementation of this SWPPP, seeks to minimize potential discharges of hazardous materials to storm water. M&M Metal Recycling, Inc. has several BMPs in place to minimize discharge of hazardous material to storm water (Table 6), and additional BMPs are planned to further control and reduce potential hazardous discharges to storm water (Table 7). The Pollution Prevention Team will routinely review the program and aggressively evaluate the program for improvement. 13

20 Activity TABLE 6 CURRENT BMPS Provide information/education of scrap recyclable materials on draining and properly disposing of residual fluids (e.g., from vehicle and equipment engines, radiators and transmissions) prior to delivery to the facility. Create a written list of materials that will not be accepted at the facility and materials that will be accepted. Reject unacceptable materials at the source. Train employees engaged in the inspection and acceptance of inbound recyclable materials. Inspect incoming materials for items on the prohibited materials/special handling list. Have truck drivers picking up loads off site conduct preliminary inspections for items on the list before hauling. Inbound recyclable materials control Check incoming scrap materials for potential fluid contents and batteries. Dispose of greasy rags, batteries, and solid waste properly. Label and track the recycling of waste materials. Store cracked batteries in a non-leaking secondary container. Only accept vehicles drained of fluids with batteries removed prior to arrival at the site. Perform inspections at the loading dock. Establish and implement procedures to educate auto scrap providers of the need to remove mercury switches from hood and trunk lighting units and antilock brake system units. Store batteries on impervious surfaces within the designated storage building. Confine storage to designated areas. Scrap material storage Train employees on procedures for storage and inspection items. Provide a manual tarping system for containers that are not in covered areas in the facility. Conduct periodic inspections. Conduct preventive maintenance as necessary. 14

21 Activity TABLE 6 CURRENT BMPS Automobiles storage area Inspect all automobiles entering the area for fluids and/or leaks. Stabilize high traffic areas (e.g., concrete pads, gravel, and pavement around processing equipment) where practicable. Scrap processing operations Schedule frequent inspections of equipment for spills or leakage of fluids, oil, fuel, and/or hydraulic fluids due to malfunctioning, worn, or corroded parts or equipment. Establish spill prevention and response procedures, including employee training. Store batteries indoors on an impervious surface. Raise batteries off the floor with pallets or store in covered, leak-proof containers. Separate all scrap batteries from other scrap materials. Scrap lead-acid battery program Establish procedures for the collection, storage, handling, and disposition of cracked or broken batteries in accordance with applicable Federal regulations (e.g., RCRA). Establish special handling procedures for cracked or broken batteries. Neutralize acid leaks with sodium carbonate, soda ash, or other absorbent materials. Establish inspection and acceptance procedures for scrap lead-acid batteries. Provide supplier training for acceptance practices for scrap batteries. Provide employee training on the safe handling, storage, and disposition of scrap batteries. Supplies for Process Equipment Locate storage containers with liquids, including oils and lubricants, indoors, and provide sufficient containment around the materials. Provide preventive maintenance of BMPs, as necessary. Instruct employees on proper storage and material handling procedures. Maintain an organized inventory of materials used on site. Good Housekeeping Prohibit the practice of hosing down an area where the practice would result in the exposure of pollutants to storm water. Clean without using liquid cleaners whenever possible. 15

22 Activity TABLE 6 CURRENT BMPS Watch vehicles closely for leaks and use pans to collect fluid when leaks occur. Conduct fueling operations on an impervious or contained pad or under a roof where possible. Use drip pans where leaks or spills can occur and where making and breaking hose connectors. Clean up spills and leaks immediately. Equipment fueling Ensure that fuel tank is inspected and appropriately labeled while in storage and prior to movement and use. Perform preventive maintenance on storage tank to detect potential leaks before they occur. Train personnel on proper fueling procedures. Use drip pans under all equipment and vehicles awaiting maintenance. Outdoor operational vehicle/equipment parking and storage Conduct inspections of parking and storage area for leaks and filled drip pans. Provide employee training. Stabilize all high traffic areas with gravel. Conduct periodic inspections and maintenance of these areas and BMPs. Perform preventive maintenance on BMPs as needed. Provide employee training on the proper installation and maintenance of erosion and sediment controls. 16

23 ACTIVITY Inbound recyclable materials control Scrap material storage Auto carcass storage area Scrap processing operations Good Housekeeping Erosion and sediment control TABLE 7 FUTURE BMPS FUTURE BMPS Within 30 days of the date of this plan, an emergency spill kit will be placed on the loading dock. Within 180 days of the date of this plan, a storm water diversion will be placed along the perimeter to prevent uncontrolled runoff. Within 180 days of the date of this plan, a storm water diversion will be placed along the perimeter to prevent uncontrolled runoff. Within 30 days of the date of this plan, a fire extinguisher and an emergency first aid kit will be placed near the propane torch cutting area. Within 30 days of the date of this plan, oil absorbent socks will be placed near outfall 001. Within 180 days of the date of this plan, areas not covered by compacted gravel or other cover will be stabilized Preventative Maintenance Preventive Maintenance involves the regular inspection, testing, and cleaning of facility equipment and operational systems. These inspections will help to uncover conditions that might lead to a release of materials, thus allowing for maintenance to prevent such a release. M&M Metal Recycling, Inc. has an aggressive program for facility equipment, loaders, forklifts, and trucks. Repair of oil leaks and replacing belts, hoses, and fluids are performed on industryaccepted schedules Good Housekeeping Good housekeeping practices are designed to maintain a clean and orderly work environment. The following will reduce the potential for significant materials to come in contact with storm water. 17

24 Label everything with the contents of the container to avoid cross-contamination and to facilitate recycling. Keep all chemicals in closed, covered or sealed containers. Always use funnels or pumps when transferring or dispensing fluids. Maintain equipment to prevent leaks and spills. Maintain trash dumpster on site and dispose of solid waste regularly. Do not burn or bury any vehicle waste. Do not store empty open containers, drums or tanks on site. Recycle/dispose of material regularly Spills and Leaks/Prevention Clean up small spills right away. Accidental spills that occur during fueling of equipment are cleaned with an oil absorbent material and stored for proper disposal. Store all used absorbents in closed, covered leak-proof containers, and dispose of properly. Store all waste fluids in closed containers to prevent spills. Close tightly to prevent evaporation. Inspect containers regularly for leaks. Develop a maintenance plan for all facility equipment, such as loaders, forklifts and trucks. Keep spill control equipment/absorbent materials in a central location, accessible to all employees. Train all employees on spill response Spill Control Equipment Fire extinguishers are required near the propane torch cutting area. Safety equipment for employees should include rubber or latex gloves and safety glasses. Use brooms, shovels and dust pans to pick up clean-up materials. 18

25 Containers to hold spill waste such as drip pans, pails, and drums should be available. When a spill occurs, follow these basic steps: 1. Observe the safety precautions associated with the material spilled. 2. Stop the source of the spill if possible and clean up the spill right away. 3. Call your local fire and/or police departments if fire or public safety hazards are created. 4. Contain the spilled material. Dirt, sand or any semi-impermeable material may be used to create a containment structure to prevent material from moving. 5. Report any spill of used oil or fuel that discharges to a water body, or any spill over 25 gallons, to the National Response Center at and the Arkansas Department of Emergency Management at Recover the spilled substance while observing safety precautions. Professional contractors may need to be hired if large quantities or dangerous substances are involved or if long-term cleanup and investigation is required Container Management and Storage Maintain containers in good condition and routinely inspect for signs of rust, leaks or defects. Prevent leaks, ruptures and the accumulation of rainwater on top of drums. Keep containers closed when not actively adding or removing material. Label all containers properly. Container leaks or spills must be stopped, contained, and managed immediately and the container repaired or replaced. Pickup bed or trailer used to store the 500-gallon diesel tank will be covered with tarp or plastic to prevent contact with storm water. Cover will be held in place with rope or bungee cords. 19

26 6.1.6 Labels Label every container with the contents and type of waste. Store containers in an area protected from weather and on a curbed impervious surface. Inspect containers at least once a week and keep a written log of container inspections. Keep manifests and shipping receipts for 3 years. Keep records of lab tests for 3 years. Keep completed land disposal restriction forms for 3 years. Get receipts to verify payment for disposal Source Area Controls To the maximum extent practicable, and to the extent it is cost effective, the use of source area control BMPs designed to prevent storm water from becoming contaminated will be used Erosion Control Measures Areas prone to soil erosion shall be protected, and the soil kept out of the storm water discharge. Erosion control measures to be considered, as deemed necessary upon routine inspection, include seeding or otherwise stabilizing bare areas, diversion of runoff, paving traveled areas, trapping sediment, protecting inlets and preventing tracking Diversions Diversions are structures (including grading and curbing) that are used to divert storm water away from high risk areas and prevent contaminants from mixing with the runoff. The following areas are to be protected through the use of diversion structures: uncut scrap metal and automobile storage areas, the loading and unloading area, and the propane torch cutting area. 20

27 6.2 Employee Training Employee training will be held in the fourth quarter of Immediately upon hiring, all new employees will be instructed in storm water pollution prevention, spill response and housekeeping procedures and annually thereafter. This training will be modified to incorporate new pollution practices that may be included into the plan. The effective implementation of the SWPPP is dependent upon employee awareness. The plan is a joint effort requiring cooperation of all facility staff. New employees will receive training on the SWPPP upon hiring, and all employees will be trained annually on the SWPP (or more often, as needed) to include: Purpose and scope of SWPPP, Spill response procedures including safety associated with response, Reporting procedures (e.g., who, what, where, how quick to report), Incoming recyclable and waste material requirements, Equipment and operator safety, Proper handling, storage, and disposal procedures, Erosion and sediment controls, Fluids management, Good housekeeping practices, Battery management and storage, Best Management Practices, Parts and Materials handling and storage. 7.0 EVALUATIONS AND INSPECTIONS 7.1 Quarterly Visual Site Inspections Qualified facility personnel will conduct routine facility inspections of all areas of the facility where industrial materials or activities are exposed to storm water, all storm water control 21

28 measures used to comply with the permit, and storm water outfalls (if accessible) for the presence of floating materials, visible sheen, discoloration, turbidity, odor, etc. Inspections will be performed not less than four (4) times a year. At least one of the four required inspections will be conducted during a period when a storm water discharge is occurring. One inspection will check for the presence of unauthorized nonstorm water discharges to the storm water drainage system. This will be done preferably during dry weather, when it is easier to find non-storm water discharges. If a non-storm water discharge is discovered, the M&M Metal Recycling, Inc. shall notify ADEQ and eliminate the illicit discharge within 30 days. M&M Metal Recycling, Inc. will document the findings of each visual inspection performed and maintain this documentation onsite with the SWPPP. At a minimum, documentation of each site inspection will include: date of inspection, personnel making the inspection, major observations, and a summary of actions that need to be taken as a result of the inspection. M&M Metal Recycling, Inc. will perform bi-annual visual inspections of the storm water outfall during rain events to look for evidence of storm water contamination. Inspections will be conducted within the first thirty minutes of discharge or soon thereafter, but not exceeding 60 minutes. The visual inspection shall include any observations of color, odor, turbidity, floating solids, foam, oil sheen, or other obvious indicators of storm water pollution. Information recorded during the quarterly inspection shall include: date of inspection, storm system inlet location, inspection results, and potential significant sources of storm water contaminants if discovered. Blank inspections forms can be found in Appendix B of this SWPPP. 7.2 Annual Comprehensive Site Compliance Evaluation Qualified personnel shall conduct site compliance evaluations at appropriate intervals specified in the SWPPP, in no case less than once per year. 22

29 a) Areas contributing to a storm water discharge associated with industrial activity shall be visually inspected for evidence of, or the potential for, pollutants entering the drainage system. Measures to reduce pollutant loadings shall be evaluated to determine whether they are adequate and properly implemented in accordance with the terms of the permit and SWPPP, or whether additional control measures are needed. Structural storm water management measures, sediment and control measures, and other structural pollution prevention measures identified in the plan shall be observed to ensure that they are properly maintained and operated correctly. A visual inspection of equipment needed to implement the spill response shall be conducted. b) Based on the results of the inspection, the description of potential pollutant sources identified in the SWPPP in accordance with Description of Potential Pollutant Sources of the permit and pollution prevention measures identified in the SWPPP in accordance with Measures and Controls of this permit shall be revised as appropriate within 30 days of such inspection. Implementation of any changes to the SWPPP made shall be performed in a timely manner, but in no case more than 90 days from the inspection. c) A report summarizing the scope of the inspection, personnel making the inspection, date(s) of the inspection, major observations relating to the implementation of the SWPPP, and actions taken shall be made and retained as part of the SWPPP. The report shall be signed in accordance with the Permit. d) The annual comprehensive site compliance evaluation may also be used as one of the routine inspections, as long as all requirements of both types of inspections are have been fulfilled. An annual comprehensive site compliance evaluation will be conducted approximately one year following implementation of this SWPPP and annually thereafter. The inspection will determine if the BMPs have been implemented and will assess their effectiveness. The 23

30 inspection will also determine if site operations have changed since development of this SWPPP. If operational changes have been made, the SWPPP Coordinator will determine if those changes will impact storm water quality and develop new BMPs to address the change. All operational changes and new BMPs will be recorded in this SWPPP. Additionally, the inspection date, the inspection personnel, the scope of the inspection, major observations, and any needed revisions will be recorded. Revisions to the plan will occur within fourteen days after the annual inspection. Blank annual compliance inspections forms can be found in Appendix B of this SWPPP. 7.3 Bi-Annual Sampling and Analyses All facilities covered under the Permit are now required to monitor effluents for ph, COD, TSS, and Oil and Grease (O & G). In addition, the Permit requires Industrial Sector N1 facilities N-1 (Scrap Recycling & Waste Recycling Facilities except Source-Separated Recycling with a SIC Code of 5093) to monitor additional Effluent Characteristics. Table 8 below identifies the Effluent Characteristics that M&M Metal Recycling, Inc. is required to monitor on a twice annual basis. TABLE 8 EFFLUENT CHARACTERISTICS MONITORING REQUIREMENTS Effluent Characteristics Parameter Benchmark Value Maximum ph Minimum: 6.0 s.u. Maximum: 9.0 s.u. Chemical Oxygen Demand (COD) Total Suspended Solids (TSS) Oil and Grease (O & G) Total Aluminum Total Copper Total Iron Total Lead Total Zinc 120 mg/l 100 mg/l 15 mg/l 0.75 mg/l mg/l 1.0 mg/l mg/l mg/l 24

31 A monitoring period is from January 1st to December 31st of each calendar year. M&M Metal Recycling, Inc. is required to sample at least twice within a calendar year. Samples must be taken from outfall 001 in each of the following time frames: January 1 through June 30. July 1 through December Sampling Procedures Samples and measurements will be taken by M&M Metal Recycling, Inc. as required and shall be representative of the volume and nature of the monitored discharge. Storm water will be sampled according to requirements below. If M&M Metal Recycling, Inc. is unable to sample during a monitoring period, justification will be provided with the Discharge Monitoring Report for that period. Sampling procedures are as follows: a. Grab Sample: A minimum of one grab sample will be taken from the outfall within the first 30 minutes of a discharge resulting from a measurable storm event as described below in Section 7.3.1(b) of this SWPPP. If it is not possible to collect the sample within the first 30 minutes of a measurable storm event, the sample will be collected as soon as practicable after the first 30 minutes and documentation will be kept with the SWPPP explaining why it was not possible to take samples within the first 30 minutes. b. Measurable Storm Events: All required monitoring will be performed on a storm event that results in an actual discharge from the site ( measurable storm event ) that follows the preceding measurable storm event by at least 72 hours (3 days). The 72-hour (3-day) storm interval will not apply if the M&M Metal Recycling, Inc. is able to document that less than a 72-hour (3-day) interval is representative for local storm events during the sampling period. For each monitoring event, the date and duration (in hours) of the rainfall event, rainfall total (in inches) for that rainfall event, and time (in days) since the previous measurable storm event will be identified. 25

32 c. Adverse Weather Conditions: Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical, such as drought or extended frozen conditions. When adverse weather conditions prevent the collection of samples according to the relevant monitoring schedule, a substitute sample will be taken during the subsequent qualifying storm event. Adverse weather does not exempt M&M Metal Recycling, Inc. from having to file a discharge monitoring report in accordance with the sampling schedule. M&M Metal Recycling, Inc. will report any failure to monitor as indicating the basis for not sampling during the usual reporting period. d. Sampling Method. Analytical methods used to meet the monitoring requirements specified in this permit shall conform to the latest revision of the Guidelines Establishing Test Procedures for the Analysis of Pollutants contained in 40 CFR Part 136 or to the latest revision of Standard Methods for the Examination of Water and Wastewater (APHA), unless otherwise specified in the permit or approved in writing by the Department provided that such otherwise approved analytical method is the equivalent of that found in the guidance cited in this section or will result in more accurate analytical results or will have a lower detection limit. e. Records and Reporting. For each monitoring event, M&M Metal Recycling, Inc. shall record and report the date and duration (in hours) of the storm event(s) sampled; rainfall measurements or estimates (in inches) of the storm event which generated the sampled runoff; the duration between the storm event sampled and the end of the previous measurable storm event; and an estimate of the total volume (in gallons) of the discharge sampled shall be provided. In the event a sample exceeds a parameter benchmark value, the facility will investigate the cause(s) and/or source(s) of elevated pollutant levels, review the SWPPP, and determine and document an action plan to address the exceedance. This action shall be taken within 30 calendar days of the exceedance. 26

33 7.3.2 Natural Background Pollutant Level M&M Metal Recycling, Inc. has identified a background sampling location (BG) to determine the natural background pollutant levels that may impact benchmark values in onsite sampled storm water. If M&M Metal Recycling, Inc. determines that the exceedances of the benchmark values is attributable solely to the presence of that pollutant in the natural background, M&M Metal Recycling, Inc. is not required to perform corrective actions or additional benchmark monitoring provided that the following are met: a. The concentration of the benchmark monitoring results is less than or equal to the concentration of that pollutant in the natural background; b. M&M Metal Recycling, Inc. documents and maintains with the SWPPP the supporting rationale for concluding that benchmark exceedances are in fact attributable solely to natural background pollutant levels. This must include in the supporting rationale any data previously collected by the facility or others (including literature studies) that describe the levels of natural background pollutants in the storm water discharge; and c. The Department must be notified on the annual report that the benchmark exceedances are attributable solely to natural background pollutant levels. Natural background pollutants include those substances that are naturally occurring in soils or groundwater. Natural background pollutants do not include legacy pollutants from earlier activity on-site, or pollutants in run-on from neighboring sources which are not naturally occurring. Compliance with the requirements of the above conditions does not relieve M&M Metal Recycling, Inc. of the duty to comply with any other applicable conditions of the permit. 27

34 7.4 Annual Update of the SWPPP The annual review of the SWPPP identifies opportunities to improve the overall program as well as update the SWPPP to reflect changes within the Permit that may affect the facility and its operations. These changes, if warranted, will be incorporated in the SWPPP and the record of change retained for three years. 8.0 COMPLIANCE AND REPORTING REQUIREMENTS 8.1 Employee Training An employee training program will be developed and implemented to educate employees about the requirements of the SWPPP. This education program will include background on the components and goals of the SWPPP and hands-on training in spill prevention and response, good housekeeping, proper material handling, disposal and control of waste, container filling and transfer, and proper storage, washing, and inspection procedures. All new employees will be trained within one week of their start date. Additionally, all employees will be required to participate in an annual refresher training course. An employee sign-in sheet for the refresher course can be found in Appendix B of this document. The training program will be reviewed annually by the SWPPP coordinator to determine its effectiveness and to make any necessary changes to the program. 8.2 Implementation Schedule In accordance with the State of Arkansas, the SWPPP implementation schedule is presented in Table 9. This schedule corresponds to the effective date of the SWPPP. 28

35 Storm Water Pollution Prevention Action Items Table 9 Implementation Schedule Implementation Date Implement employee training Non-storm water discharge assessment Quarterly visual monitoring Immediate Immediate September 1, 2012; December 1, 2012; March 1, 2013; June 1, 2013; and quarterly thereafter Implementation of BMPs See Table 7 One sample from each outfall will be collected Bi-annual sampling and analysis Annual facility site compliance inspection during each of the following time frames: Jan. 1 through June 30 July 1 through Dec. 31 December 1, 2012 and annually thereafter 8.3 Record and Reporting Requirements Records M&M Metal Recycling, Inc. shall retain records of all monitoring information, inspection reports, the SWPPP, the Notice of Intent (NOI), and any other documentation of compliance with permit requirements for a period of at least 3 years from the date that coverage under the permit expires or is terminated. Such information shall include all calibration and maintenance records and all original recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for the permit. This period of retention shall be extended during the course of any unresolved litigation regarding the discharge of pollutants by M&M Metal Recycling, Inc. or when requested by ADEQ. 29

36 8.3.2 Records Contents For each measurement or sample taken, the M&M Metal Recycling, Inc. shall record the following information: (1) the date, exact place, method, and time of sampling or measurement; (2) the individual who performed the sampling or measurement; (3) the dates the analyses were performed; (4) the individual who performed the analyses; (5) the analytical techniques or methods used; and (6) the results of all analyses Reporting a. Discharge Monitoring Reports: M&M Metal Recycling, Inc. will record the monitoring results obtained from monitoring during the previous twelve (12) months on Discharge Monitoring Report (DMR) Forms dated no later than the 31st day of the month following the completed period. Reports are due by the 31st day of January each year for the previous January December reporting period (i.e. January 31, 2013 for Year 2012). Signed copies of Discharge Monitoring Reports required above, and all other reports required herein, shall be submitted to the Department. b. Annual Report. M&M Metal Recycling, Inc. will submit an annual report to the Department, even if monitoring requirements have been waived, that includes the findings from the comprehensive site evaluation and site inspections (including visual monitoring of outfalls) and any corrective action plans. M&M Metal Recycling, Inc. will include the status of any corrective actions not yet completed at the time of submission of this annual report. The annual report should also include the following: Facility name, General permit tracking number, facility physical address, and contact person name, title, and phone number. Reports are due by the 31st day of January each year for the previous January December reporting period. All annual reports must be signed in accordance with the provisions of 40 CFR , as adopted by reference in APCEC Regulation No. 6, and 30

37 Part 6.9 of the Permit. M&M Metal Recycling, Inc. will submit its annual report with the Discharge Monitoring Reports. 8.4 Provisions for Amendment of the Plan If the facility expands, experiences any significant production increases or process modifications, or changes any significant material handling or storage practices which could impact storm water, the SWPPP will be amended appropriately. The amended SWPPP will have a description of the new activities that contribute to the increased pollutant loading and planned source control activities. The SWPPP will also be amended if the state or federal compliance inspection officer determines that it is ineffective in controlling storm water pollutants discharged to waters. 8.5 SWPPP Availability M&M Metal Recycling, Inc. will retain a copy of the current SWPPP required by the permit at the facility, and it will be immediately available to ADEQ and representatives of the U.S. Fish and Wildlife Service (USFWS) at the time of an onsite inspection or upon request. 31

38 Storrr Water Pollution prevention plan 9.0 CERTIFICATION OF THE SWPPP "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the Person or Persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accutate' and complete. I am aware that there are significant penalties for submitting false information, induding the possibility of fine and imprisonment for knowing vio1arions.,, Matt Stiles, Owner/ Operator Date (Signature of Plan Preparer) (Printed Name/Title) (Date) 32

39 APPENDIX A FIGURES

40 6159 Heber Springs Rd., Drasco, Arkansas SWPPP Contact: Matt Stiles (870) SITE FIGURE 1 SITE VICINITY LOCATION MAP Facility Latitude: N Facility Longitude: W

41 6159 Heber Springs Rd., Drasco, Arkansas SWPPP Contact: Matt Stiles (870) N Symbols: BG 01 Outfall/Sample Point BG Background Sample Point Stormwater Flow Path Propane Torch Area ane Torch Area Total Facility Size (acres): 4.5 Not to Scale 01 Impervious Surface Estimate (% of total facility area): 2% Total Facility Size (acres): 4.85 Not to Scale FIGURE 2 SITE DRAWING

42 Surface Water Flow FIGURE 3 SITE DRAINAGE AREA MAP