The Client authorized W&M Environmental (now a part of Braun Intertec) to provide annual regulatory compliance assistance with stormwater, regulatory reporting, and other environmental compliance services for nine Client Sites throughout Texas and Oklahoma.
Our team has worked with this family of scrap metal facilities for approximately 10 years. Scrap metal facilities are subject to Multi-Sector General Permit (MSGP) Industrial Stormwater permits, 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, we assist their facilities with Stormwater Pollution Prevention Plan (SWPPP) assistance (inspections, best management practice (BMP) evaluation, analyzing data, annual reporting, etc.), preparation of their Tier II reports, air permitting assistance and documentation, and technical assistance on various environmental projects.
Over the last decade, we have created and helped implement SWPPPs for each of the company’s facilities during each year of the 5-year permit cycle. SWPPP assistance includes quarterly and/or annual inspections, regular review and revisions of the SWPPP (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, Braun Intertec has helped the facilities track, review, assess, and document the trends in metal concentrations being discharged from their operations. Through hard work, constant improvement, and Client ownership of their environmental responsibilities, we have helped the business to gradually reduce the concentrations being discharged. Our team has also provided active support for city and TCEQ inspections and scheduled meetings with regulators at the facilities. We also created SPCC plans for all the facilities exceeding the 1,320 gallon threshold for oils. We have trained applicable on-Site personnel on SWPPP 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. Our team has prepared the Tier II reports for each facility. These scrap metal facilities rely on us to help them maintain their compliance and are in constant communication with our team members, updating us if something is changing and using our experienced staff as a sounding board.
