On-going Annual Compliance Assistance
The Client authorized W&M Environmental (W&M) to provide annual regulatory compliance assistance with stormwater, regulatory reporting, and other environmental compliance services for nine Client Sites throughout Texas and Oklahoma.
W&M has worked with this family of scrap metal facilities for approximately 9 years. Scrap metal facilities are subject to Multi-Sector General Permit (MSGP) Industrial Stormwater permit, as well as a handful of other environmental regulations ranging from Emergency Planning Community Right-to-Know Act (EPCRA) Tier II reporting, air permitting, Spill Prevention, Control, and Countermeasure (SPCC), and non-hazardous waste generation. Each year, W&M assists their facilities with Stormwater Pollution Prevention Plan (SWP3) assistance (inspections, best management practice (BMP)evaluation, analyzing data, annual reporting, etc.) and preparation of their Tier II reports, air permitting assistance and documentation (as needed), and technical assistance on various environmental projects throughout the year.
Throughout the last 9 years, W&M has created and helped implement SWP3s for each of the company’s facilities during each year of the 5-year permit cycle. SWP3 assistance includes quarterly and/or annual inspections, regular review and revisions of the SWP3 (as needed), record retention, BMP development and assessment, preparing and submitting the annual Benchmark Monitoring (BM) and Discharge Monitoring Reports (DMRs), as well as any city or locally required reporting. Over time, W&M has helped the facilities track, review, assess, and document the trends in metals concentrations being discharged from their operations. Through hard work, constant improvement, and Client ownership of their environmental responsibilities, W&M has helped the business to gradually reduce the concentrations being discharged. W&M has also provided active support for city and TCEQ inspections and scheduled meetings with regulators at the facilities. W&M has also created SPCC for all the facilities exceeding the 1,320 gallon threshold for oils. W&M has trained applicable on-Site personnel on SWP3 and SPCC requirements and maintenance of the plans.
These facilities also recycle lead-acid batteries and oils, and some have large amounts of welding or torching gases. As such, all 9 of the facilities are required to submit a Tier II report to the TCEQ, Local Emergency Planning Committee (LEPC), and the local fire department. W&M has prepared the Tier II reports for each facility. These scrap metal facilities rely on W&M to help them maintain their compliance and are in constant communication with W&M, updating us if something is changing and using our experienced staff as a sounding board.