Osprey Environmental SWPPP Holly Hill Facility 16 April 2026.pdf

STORMWATER POLLUTION PREVENTION PLAN

TOWN OF GREENWICH – HOLLY HILL RESOURCE RECOVERY FACILITY

99 HOLLY HILL LANE

GREENWICH, CT

MARCH 2026

Prepared for:

TOWN OF GREENWICH

Department of Parks & Recreation

Prepared by:

Osprey Environmental Engineering, LLC.

Clinton, Connecticut

SIGNATURE OF REPORT AUTHOR

This plan has been prepared by Osprey Environmental Engineering, LLC. This plan documents facility conditions as of the date indicated, and is based, in part, on information obtained from facility personnel.

Questions or comments on the contents of this report should be directed to the individual listed below.

Prepared by:

31 March 2026 Robert Grabarek, P.E., L.S. Date President

Note: SWPP Plan certifications are included in Appendix A.

TABLE OF CONTENTS

EMERGENCY CONTACT AND NOTIFICATION LIST..............................................................................................iv

1.0 INTRODUCTION

2.0 FACILITY DESCRIPTION

2.1 FACILITY INFORMATION

2.2 FACILITY DESCRIPTION

2.3 INVENTORY OF POTENTIAL POLLUTANT SOURCES

2.3.1 VESSEL MAINTENANCE AND WASHING

2.3.2 OUTSIDE STORAGE

2.3.3 OTHER POTENTIAL POLLUTANT SOURCES

2.4 SPILL HISTORY

2.5 PAST STORMWATER SAMPLING DATA

3.0 STORMWATER POLLUTION PREVENTION TEAM

3.1 TEAM MEMBERS AND INDIVIDUAL RESPONSIBILITIES

3.2 TEAM RESPONSIBILITIES

4.0 STORMWATER MANAGEMENT

4.1 FACILITY DRAINAGE

4.2 STORMWATER CONTROL MEASURES

4.2.1 GOOD HOUSEKEEPING

4.2.2 MINIMIZE EXPOSURE

4.2.3 VEHICLES AND EQUIPMENT

4.2.4 LIQUID AND WASTEWATER CONTAINMENT

4.2.5 SPILL PREVENTION AND RESPONSE

4.2.6 DUST CONTROL MEASURES

4.2.7 SEDIMENT AND EROSION CONTROL

4.2.8 MANAGEMENT OF STORMWATER

4.2.9 PREVENTIVE MAINTENANCE

4.2.10 SOLID DE-ICING MATERIAL STORAGE

4.2.11 INFILTRATION AND GROUNDWATER PROTECTION

4.2.12 INACTIVE SITE CONTROLS

4.2.13 SECTOR-SPECIFIC CONTROL MEASURES

4.2.14 RESILIENCE MEASURES

4.2.15 FUTURE CONSTRUCTION

4.2.16 NON-STORMWATER DISCHARGES

4.3 STORMWATER MONITORING PROGRAM

4.3.1 GENERAL OVERVIEW

4.3.2 SCHEDULES AND TEST PARAMETERS

4.3.3 SAMPLE COLLECTION

4.3.4 RECORDKEEPING AND REPORTING REQUIREMENTS

4.4 CORRECTIVE ACTION MEASURES

4.4.1 CAM LEVEL 1

4.4.2 CAM LEVEL 2

4.4.3 CAM LEVEL 3

4.4.4 WAIVERS

4.4.5 DOCUMENTATION IN SWPP PLAN

5.0 TRAINING, INSPECTIONS AND RECORDKEEPING

5.1 TRAINING

5.2 INSPECTIONS

5.2.1 ROUTINE INSPECTIONS

5.2.2 STORMWATER VISUAL INSPECTIONS

5.2.3 COMPREHENSIVE INSPECTIONS

5.3 RECORDKEEPING

6.0 PLAN REVIEW AND AMENDMENT

7.0 IMPLEMENTATION ITEMS

FIGURES

FIGURE 1 SITE LOCATION

FIGURE 2 SITE PLAN

APPENDICES

APPENDIX A CERTIFICATIONS

SPILL NOTIFICATION PROCEDURES

SPILL RESPONSE DOCUMENTATION LOG

REPORT OF PETROLEUM/CHEMICAL PRODUCT DISCHARGE, SPILLAGE OR RELEASE

APPENDIX B STORMWATER REGISTRATION

APPENDIX C INSPECTION LOGS AND FORMS

ROUTINE FACILITY INSPECTION

STORMWATER QUALITY

COMPREHENSIVE INSPECTION

APPENDIX D TRAINING AND PLAN REVISIONS LOGS

TRAINING LOG

REVISIONS LOG

APPENDIX E SPILL NOTIFICATION AND DOCUMENTATION FORMS

SPILL NOTIFICATION PROCEDURES

SPILL RESPONSE DOCUMENTATION LOG

REPORT OF PETROLEUM/CHEMICAL PRODUCT DISCHARGE, SPILLAGE OR RELEASE

SUMMARY OF HISTORICAL FACILITY SPILLS

APPENDIX F STORMWATER SAMPLING FORMS AND RESULTS

SUMMARY OF PAST STORMWATER SAMPLING DATA

STORMWATER SAMPLING DATA

DISCHARGE MONITORING REPORTS

APPENDIX G REGULATORY CROSS-REFERENCE TABLE

EMERGENCY CONTACT AND NOTIFICATION LIST

Holly Hill Resource Recovery Facility Greenwich, Connecticut

Stormwater Pollution Prevention Team

Name Title Office Cell

Patrick Collins Team Leader

Operations Manager 203 869 6910 x2 203 524 3783

Anthony Rhaney Alternate Team Leader

203 869 6910 x3

Robert Grabarek Team Member 860 669 8651 -

Federal, State and Local Agencies

Greenwich Fire Department 911

Greenwich Police Department 911

Connecticut Department of Energy & Environmental

Protection (CT DEEP) Spill Hotline 866-337-7745 (24 hr.)

National Spill Response Center 800-424-8802 (24 hr.)

Spill Response Contractors and Other Services

Clean Harbors

General 800 899 4672 Liz Orluk 860 993 5826 Fern Centeno 860 906 6634

Greenwich Hospital 203 863 3005

Osprey Environmental 203 627 4998

1.0 INTRODUCTION

This Stormwater Pollution Prevention (SWPP) Plan has been prepared for Holly Hill Resource Recovery Facility (the

Facility) located at 99 Holly Hill Lane in Greenwich, Connecticut. This Plan has been prepared in accordance with the

Connecticut Department of Energy & Environmental Protection (CT DEEP) General Permit for the Discharge of

Stormwater Associated with Industrial Activities (Stormwater IGP), effective November 1, 2025, which requires a

SWPP Plan.

The Stormwater IGP is applicable if a facility meets the following qualifications:

The facility meets the definition of “industrial activity”. Under the Stormwater IGP, “industrial activity” includes numerous Standard Industrial Classification (SIC) codes and descriptive categories. x YES NO

Facility SIC code (Appendix A): 4953 (Refuse Systems)

Sector of Industrial Activity: L

The facility discharges stormwater that may come into contact with an “industrial activity”. Any stormwater associated with an “industrial activity” on site is included. x YES NO

Industrial activities at the facility include outside material and waste storage which are exposed to stormwater.

As the facility is a covered “industrial activity” and it conducts industrial activities which are exposed to stormwater, it is required to register under the Stormwater IGP and prepare a SWPP Plan. The stormwater registration is presented in

Appendix B. Holly Hill Resource Recovery Facility registered under the Stormwater IGP in March 2026.

This SWPP Plan describes the procedures, methods and equipment used to prevent the contamination of stormwater. A table which cross-references the requirements of the Stormwater IGP with the location of each requirement within this

Plan is included in Appendix G. This Plan is intended to meet the planning requirements of this regulation and, as such, a copy of this Plan will be kept on site at all times.

Additionally, a sign or other notice of permit coverage will be posted at a safe, publicly accessible location in close proximity to the Facility containing the following information (Section 4.2.16.3):

Name of Permittee:

Site address;

A contact name;

Contact email and phone number;

The Facility NPDES ID number;

The Permittee-hosted website where the Registration and SWPP Plan are available; and

“If you observe stormwater pollution from this site, please contact the CT DEEP at Report Water Pollution at www.ct.gov/deep/stormwater.”

The sign will be at least 2-feet by 3-feet in dimension, weatherproof, in English and Spanish, and located so it is visible

Stormwater Pollution Prevention Plan 7 Town of Greenwich Holly Hill Resource Recovery Facility Osprey Environmental Engineering 99 Holly Hill Lane, Greenwich, CT from a public road.

2.0 FACILITY DESCRIPTION

2.1 FACILITY INFORMATION

Name: Holly Hill Resource Recovery Facility

Address: 99 Holly Hill Lane, Greenwich, CT

Phone No.: 203 869-6910

Facility Operations: Transfer Station

Owner/Operator: Town of Greenwich, 101 Field Point Road, Greenwich, CT 06830

Primary Contact: Patrick Collins Work: 203 869 6910

Alternate Contact: Robert Grabarek Work: 860 669 8651

2.2 FACILITY DESCRIPTION (Section 4.3.2.a)

The subject parcel is 27.4 acres in size and is located on Holly Hill Lane in Greenwich, Connecticut. It is bounded to the north by commercial properties, to the east and west by residentially developed parcels, and to the south by a recreational field

The Facility has been in operation at this site for over 100 years. This facility is a municipal solid waste recycling facility and transfer station. Municipal solid waste, recyclables, construction debris, and wood debris are brought to the facility and sorted for final disposal off-site. Recyclables are not shredded, crushed, or processed at the facility.

The facility does not accept hazardous wastes. Select special wastes and select universal wastes are accepted as noted in this plan. The facility is served by public water and sewer connections. The location of the Facility is shown on the Site Location, Figure 1 (Section 4.3.2.b). Structures and operations potentially exposed to stormwater are shown on the Site Plan, Figure 2 (Section 4.3.2.c).

2.3 INVENTORY OF POTENTIAL POLLUTANT SOURCES

The following describes the activities at the Facility which may be exposed to precipitation. (Section 4.3.2.4) Diesel Fuel Tank – A 2,000 gallon above-ground double walled steel storage tank is located near the retention basin. It is equipped with a pump and meter, and protected by blocks.

Gasoline Fuel Tank – A 2,000 gallon above-ground double walled steel storage tank is located near the retention basin. It is adjacent to the diesel tank, and has the same protective measures.

Diesel Fuel Tank – An 800 gallon above-ground double walled steel storage tank is located near the retention basin (Tom's Brook). It has the same protective measures as the other tanks.

Covered Salt Storage - 1,000 tons of salt for deicing is located on the eastern side of the site, downhill from the office trailer and south of the ballpark. It is covered with a permanent rigid structure.

Brine Solution Storage - A 6,000 gallon above-ground double walled storage tank is located next to the covered salt structure.

Scrap Metal Recycling Area – Scrap metal is placed by facility clients in an area enclosed on three sides by masonry block walls. The material is examined by facility staff prior to loading it into a trailer. Other wastes

Stormwater Pollution Prevention Plan 8 Town of Greenwich Osprey Environmental Engineering Holly Hill Resource Recovery Facility

(propane cylinders, wood debris, etc.) are segregated for disposal on impervious ground surfaces in other areas of the yard for proper disposal.

Demolition Debris/Wood Product Recycling Area – Waste wood products (old furniture, wallboard, etc., and demolition debris are placed by facility clients in an area enclosed on three sides by masonry block walls. The material is examined by facility staff prior to loading it into a 1,000 yard trailer container. Other wastes are segregated on impervious ground surfaces by facility staff prior to loading wastes into a 1,000 yard trailer.

Yard Waste Recycling Area – Yard wastes (organic matter) are placed by facility clients in an area enclosed on three sides by masonry block walls. The material is examined by facility staff prior to loading it into a 1,000 yard trailer container. Inappropriate wastes are segregated by facility staff prior to loading wastes into a 1,000 yard trailer.

Battery storage bin – A covered battery storage bin is maintained at the site for the collection of waste batteries.

The bin serves as containment if any batteries leak.

Tire storage bin - a tire storage bin is present for the collection/transfer of waste tires. It is kept covered during precipitation events.

Glass, cans, and paper/cardboard storage bins – single stream storage bins are present for the collection/transfer of waste glass metal cans, and paper/cardboard materials. They are kept covered during precipitation events.

Compressed gas cylinders – waste cylinders are kept in a secured fenced area. These are periodically recycled.

Secured storage area – Fluorescent light bulbs, spill response equipment storage and other site equipment are stored in an enclosed storage unit. All materials are under cover of the roof. Fluorescent bulbs are stored in cardboard containers located on a spill skid, and are periodically shipped off-site for recycling. Other materials in the enclosure include spill response equipment and other general site equipment.

Wood debris – stumps, logs, and other large wood yard wastes are stored for grinding/recycling.

Road Maintenance Waste Pile – a pile of soil collected from street sweepings is maintained at the site. The pile is enclosed on three sides by masonry block units.

Animal Freezer – this is an enclosed refrigeration unit for storing animal carcasses.

Mixed paper, bottle, and battery recycling containers – these are trailers used for collecting wastes from the public.

Asphalt pile – The Town has a pile of asphalt materials generated from road projects that is stored on the parcel.

Sand/salt transport and spreading equipment

TABLE 1 - POTENTIAL POLLUTANT SOURCES FROM INDUSTRIAL ACTIVITIES

Activity Location Pollutants

2,000 gallon gasoline & diesel

ASTs with fuel dispensers

North of sedimentation pond Gasoline and diesel

Diesel fuel tank - double-walled

800 gallons

Tipping house outside lower level Diesel

Salt storage - 1,000 tons Inside salt storage shed salt

Brine tank -2,000 gallon double walled

Outside salt storage shed salt solution

Recycling - scrap metal Paved yard draining to sedimentation pond oils, metals

Recycling - demolition debris wood

Paved yard draining to sedimentation pond paint, metals

Stormwater Pollution Prevention Plan 9 Town of Greenwich Holly Hill Resource Recovery Facility

Recycling - yard waste and wood debris - compost

Paved yard draining to sedimentation pond organic materials

Recycling - road maintenance waste pile

Paved yard draining to sedimentation pond asphalt

Recycling - glass, cans, paper and cardboard

100 yard trailers at north yard organic materials

Battery and tire storage bins Paved yard draining to sedimentation pond covered

Compressed gas cylinders Paved yard draining to sedimentation pond

Secured storage area - light bulbs, animal freezer

Paved yard draining to sedimentation pond

Waste 500-gallon double walled oil and 150 gallon antifreeze tanks

Inside trash building -

MSW (municipal solid waste) Inside trash building -

The subsections below discuss the activities in the table above and others at the Facility which could potentially cause stormwater pollution.

2.3.1 COLLECTION CONTAINERS AND SYSTEMS FOR WHITE GOODS AND OTHER WASTE MATERIAL STORAGE AREAS

Containers are covered during rain events. Other waste recycling material storage areas are sorted and loaded in trailers that are covered during rain events. The primary recycling yard area runoff drains to a sedimentation pond prior to discharging to the sanitary sewer.

2.3.2 SAND/SALT STORAGE

The sand/salt storage area is enclosed in a building with a roof enclosure. Sand/salt materials are kept inside the building to avoid runoff impacts.

2.3.3 SAND, GRAVEL, RIPRAP STOCKPILES

These stockpiles are contained within block enclosures to minimize unintentional transport during unloading and loading operations.

2.3.4 GASOLINE AND DIESEL BULK TANK FILLING AND VEHICLE DISPENSER FILLING

The potential for spills of petroleum during tank fills and vehicle fueling exists at the fueling island located south of the highway garage. In the case of fuel tank refilling, the licensed commercial contractor is required by the

Connecticut Department of Energy and Environmental Protection to have on hand absorbent materials and other equipment for spill containment and cleanup. A member of the Pollution Prevention Team accompanies the contractor while the tanks are refilled.

Stormwater Pollution Prevention Plan 10 Town of Greenwich

2.4 SPILL HISTORY (Section 4.3.2.4.b)

Per the Stormwater IGP, spills and leaks of 5 gallons or more of toxic or hazardous substances that occurred at the

Facility in the past three years should be included in the spill history. A discharge record log is included in Appendix

E. According to the site contact, Holly Hill Resource Recovery Facility has not had any reportable spills in the past

5 years.

2.5 PAST STORMWATER SAMPLING DATA (Section 4.3.2.7)

Per the Stormwater IGP, all past stormwater sampling data must be summarized for the Facility. A summary of this data is presented in Appendix F.

3.0 STORMWATER POLLUTION PREVENTION TEAM (Section 4.3.2.2)

3.1 TEAM MEMBERS AND INDIVIDUAL RESPONSIBILITIES

The Stormwater Pollution Prevention Team at The Facility includes the members indicated in the Emergency Contact

List at the beginning of this document. These members are either on site or on call at all times and their responsibilities include the following:

Team Leader

Responsibilities: Coordinate all stages of Plan development, inspections and implementation; coordinate training program; keep all records and ensure appropriate submittals; oversee sampling program.

Alternate Team Leader

Responsibilities: Assist the Team Leader with implementation of the Plan.

Team Member

Responsibilities: Assist with the implementation of the Plan and inspection documentation.

3.2 TEAM RESPONSIBILITIES

The Stormwater Pollution Prevention Team is familiar with all aspects of this Plan and facility processes and activities, as well as the location of and characteristics associated with oil and chemical substances handled and stored at the facility. They are also familiar with the location of records pertinent to the SWPP Plan within the facility and the facility layout.

The Team is responsible for Plan development, maintenance and implementation. Team responsibilities include:

Develop and implement Control Measures inspection and review procedures;

Conduct or oversee regular compliance inspections of the facility and assure documentation and review of these

Stormwater Pollution Prevention Plan 11 Town of Greenwich Holly Hill Resource Recovery Facility inspections;

Review analytical data from storm events for compliance with regulations;

Review new construction or facility modifications or changes, as necessary;

Make changes in procedures, as necessary, and proper notifications, if required; and

Update or revise the SWPP Plan, as necessary.

4.0 STORMWATER MANAGEMENT

Section 4.0 presents a description of stormwater management at the Facility and stormwater procedures implemented by facility personnel. This section is divided into three subsections which discuss (1) Facility Drainage, (2) Control

Measures and (3) Stormwater Monitoring. These subsections are presented below.

4.1 FACILITY DRAINAGE

Runoff Area 1 - 1.4 acre - Runoff from the south-central portion of the site flows to the stream via a 15” reinforced concrete pipe to the sediment pond basin. Situated within this watershed are the enclosed mixed solid waste building and the fuel storage tanks/pumps.

Runoff Area 2 - 2.2 acres - Runoff from the northeastern portion of the parcel flows to catch basins, the outfall of which discharges to the stream via a 15” reinforced concrete pipe to the sediment pond basin. Situated within this watershed are a grass hillside, a covered sand/salt storage shed, a brine storage tank, uncovered stone and dirt stockpiles, and a paved parking area used for truck storage.

Runoff Area 3 - 1.4 acres - Runoff from the north-central portion of the parcel flows into catch basins and through a

15” reinforced concrete pipe to the sediment pond basin, approximately 60 feet northwest of the basin discharge outfall. Situated within this watershed are the office trailer, waste 1,000 yard trailers, other storage trailers for clothes and book recycling, and a parking area.

Runoff Area 4 - 0.8 acre - Runoff from a paved area south of the recycling yard runs by sheet flow to a low spot at the southerly end of the site. This area contains a small amount of pavement upon which are stored pavement millings and stockpiles from Town Highway activities. It is

Runoff Area 5 - 0.5 acre - Runoff from pavement and a grassed area flow along a swale down the access drive and behind the Tipping House to Muskrat Brook through a sedimentation pond.

Two additional runoff areas are present at the site - the apron in front of the Tipping House and its roof which discharge through oil/water separators to the sanitary sewer; and the paved area west of Runoff Area 1 that contains bins for the collection and sorting of recyclables which drains to the large sedimentation pond and then through a

Stormwater Pollution Prevention Plan 12 Town of Greenwich high level overflow to the sanitary sewer. Both have been reviewed by the Town Wastewater Division.

Outfall Location #1

It transmits runoff at a point discharge into the sediment pond. It has coordinates of 41.0143339, -73.646297.

Outfall Location #2

It transmits runoff at a point discharge into the sediment pond. It has coordinates of 41.0142104, -73.645945.

Outfall Location #3

It transmits runoff at a point discharge into the sediment pond. It has coordinates of 41.01414393, -73.646273.

4.2 STORMWATER CONTROL MEASURES (Section 4.3.2.5.f and (Section 4.2))

The Control Measures discussed in this section are those adopted by the CT DEEP and presented in the Stormwater IGP.

These Control Measures have also been adopted by the facility for management of its stormwater. Any modifications to these practices by the facility will be evaluated carefully in order to ensure compliance with appropriate regulations.

4.2.1 GOOD HOUSEKEEPING (Section 4.2.2)

Good housekeeping is used to maintain a clean and orderly workplace and to reduce the potential for accidental spills or releases of materials that could contaminate stormwater. Garbage and waste materials are properly disposed in a timely fashion. Paved areas are swept by a street sweeper every Wednesday. Outdoor trash receptacles are not present at the site. Both buildings are equipped with HVAC vents. Building 2 is equipped with roof drains that discharge to the catch basin drainage system in the area. These drains and vents are inspected as necessary.

4.2.2 MINIMIZE EXPOSURE (Section 4.2.3)

In an ongoing effort to minimize outside storage, some equipment and supplies are stored inside buildings. When materials are stored outside, they are stored in areas where stormwater runoff does not flow off site or the materials are covered with tarps. Vessels stored outside during the off-season typically are covered with tarps or shrink wrap.

4.2.3 VEHICLES AND EQUIPMENT (Section 4.2.6)

Vehicle maintenance is not conducted at the site. Facility site maintenance equipment is serviced inside the building so no stormwater exposure is present with these activities.

4.2.4 LIQUID AND WASTEWATER CONTAINMENT (Section 4.2.4)

Maintenance chemicals for facility service activities are stored inside Building 1 and equipped with secondary containment.

4.2.5 SPILL PREVENTION AND RESPONSE (Section 4.2.8)

The Stormwater Pollution Prevention Team is the designated group accountable for spill prevention at the facility.

These people are identified in the contact table at the front of this Plan. Drums of waste maintenance fluids, such as used oil and used antifreeze, are stored in appropriate containers and are properly labeled. The containers are located

Stormwater Pollution Prevention Plan 13 Town of Greenwich Holly Hill Resource Recovery Facility in Building 1. Waste storage containers are equipped with secondary containment. In the event of a spill of petroleum or hazardous chemicals, facility personnel will utilize available spill response equipment to clean up the spill. The facility maintains spill response equipment in Building 1. Fire extinguishers are also located in the buildings. If necessary, the Stormwater Pollution Prevention Team will contact a spill response contractor to assist with the clean-up.

In the event of any release of any quantity, the Stormwater Pollution Prevention Team will immediately notify the

CT DEEP by calling 866-337-7745. If requested by CT DEEP, the facility will prepare and submit to the CT DEEP a completed “Report of Petroleum or Chemical Product Discharge, Spillage or Release”. This Report should be submitted within 48 hours of discovering the release. A copy of the Report and instructions for completing it are provided in Appendix E.

If the spill may violate applicable water quality standards, causes a film or sheen on or discoloration of surface water, or causes a sludge or emulsion to be deposited beneath the surface of the water, then the facility will immediately notify the National Response Center (NRC) at 800-424-8802. Refer to Appendix E for more information.

4.2.6 DUST CONTROL MEASURES (Section 4.2.5)

As there are no dust issues at the Facility, there are no dust control measures in place.

4.2.7 SEDIMENT AND EROSION CONTROL (Section 4.2.9)

There is little potential for soil erosion at the facility. The site is generally flat and paved or covered with gravel. It is not likely that these areas pose a sediment or erosion risk. As part of the Comprehensive Inspection, facility personnel inspect unpaved areas to assure that soil erosion does not become an issue at the facility.

4.2.8 MANAGEMENT OF STORMWATER (Section 4.2.11)

Stormwater is managed by keeping paved surfaces free of sediments and spillage. The Tipping House apron is swept with a street sweeper weekly. Landscaped areas are maintained to minimize erosion. No other runoff management practices are used at the facility.

4.2.9 PREVENTIVE MAINTENANCE (Section 4.2.10)

Facility equipment, including secondary containment, is regularly inspected for any signs of wear and tear. Items are appropriately repaired or replaced as needed. Catch basins are not present at the site.

4.2.10 SOLID DE-ICING MATERIAL STORAGE (Section 4.2.7)

Sand and salt storage is covered, and the pavement outside the access door is swept to remove any spilled materials.

Stormwater Pollution Prevention Plan 14 Town of Greenwich

4.2.11 INFILTRATION AND GROUNDWATER QUALITY PROTECTION (Section 4.2.12)

Aside from allowing stormwater generated in unpaved areas to infiltrate, no other infiltration practices are employed at the Facility. The site is not within mapped aquifer protection areas and due to the presence of the municipal potable water distribution system present in the area it is not believed that private wells are present in the surrounding area.

4.2.12 INACTIVE SITE CONTROLS (Section 4.2.14)

The facility is always in active use throughout the year.

4.2.13 SECTOR-SPECIFIC CONTROL MEASURES (Section 4.2.15)

Sector L additional control measures include the following: Inspections of Transfer Stations and Recycling Facilities

The permittee must inspect transfer stations at least once every seven days. A qualified inspector shall focus on areas of used for storage of material and wastes that are exposed to precipitation, locations where equipment and waste trucks enter and exit the site, and areas where waste and materials are loaded and unloaded. Additionally, the permittee shall conduct a daily site “walkthrough” for litter focusing on the site perimeter, cover

4.2.14 RESILIENCE MEASURES (Section 4.3.8)

In the event of an imminent threat of a hurricane all objects subject to high wind will be secured to prevent damage.

Any exterior stored liquids will be relocated to an indoor storage area to prevent disturbance or damage resulting in potential releases.

4.2.15 FUTURE CONSTRUCTION (Section 4.3.11)

The facility will avoid, wherever possible, the use of copper or galvanized roofing or building materials for any new building construction where these materials will be exposed to stormwater.

4.2.16 NON-STORMWATER DISCHARGES (Sections 4.3.2.4.c, 4.3.2.5.c)

The stormwater drainage system at the Facility was observed by Osprey on February 3, 2026 to determine if there were any non-stormwater related discharges occurring. All stormwater outfalls were dry. There did not appear to be any non-stormwater discharges occurring at the facility.

4.3 STORMWATER MONITORING PROGRAM (Section 4.3.2.7)

The Stormwater IGP specifies required stormwater monitoring. The stormwater monitoring program for the Facility is as follows.

4.3.1 GENERAL OVERVIEW (Section 4.3.2.7.a)

The facility consists of three point source stormwater discharge locations (Outfall 1, 2 & 3) as depicted on the Site

Stormwater Pollution Prevention Plan 15 Town of Greenwich Holly Hill Resource Recovery Facility

Plan, Figure 2. The Stormwater Monitoring Program outlined in the Stormwater IGP specifies that the facility is required to fulfill stormwater sampling and analytical testing requirements associated with stormwater discharge from these outfalls. Stormwater discharges in other drainage areas are substantially the same as those listed above and the proposed sample locations are most representative of site runoff so stormwater will not be sampled in the other drainage areas.

4.3.2 SCHEDULES AND TEST PARAMETERS (Sections 4.3.2.7.c and d; 4.5.1 and 2; 4.5.5)

The Stormwater IGP requires semi-annual testing and specifies the parameters to be analyzed in the stormwater outfall sample. Table 3 summarizes the parameters to be tested for in the stormwater sample collected from the outfall.

The facility is subject to effluent limitations. YES x NO

The facility is subject to the following effluent limitations: Not applicable

Stormwater from the facility discharges to the following waterbody: Tom's Brook

This waterbody has the following surface water classification. B

The area of this waterbody to where stormwater from the Facility discharges is designated as an impaired waterbody.

YES x NO

This waterbody is impaired due to the presence of the following contaminants: Not applicable

Is this discharge within 500 feet of a tidal wetland? YES x NO

Does this facility have new or increased discharges to High Quality Waters? YES x NO

Stormwater Pollution Prevention Plan 16 Town of Greenwich

TABLE 2

Stormwater Sampling Parameters and Numeric Limits

Sampling Parameter (1) Regulatory

Criteria Sampling Frequency

Chemistry

[S.U.] (2)

Uncontaminated Rainfall pH NE (3) Semi-annually (4)

Stormwater pH 5-9 Semi-annually

[mg/L] (5)

Total Aluminum (6) 0.75 Semi-annually

Total Copper (7) NE (0.059 mg/l) Semi-annually (Cu limit for this facility)

Total Iron (6) 1.0 Semi-annually

Total Lead 0.076 Semi-annually

Total Zinc 0.160 Semi-annually

Total Suspended Solids 90 Semi-annually

Total Oil and Grease 5 Semi-annually

Chemical Oxygen Demand 75 Semi-annually

Total Phosphorous - P 0.40 Semi-annually

Total Kjeldahl Nitrogen 2.30 Semi-annually

Nitrate - N 1.10 Semi-annually

Aquatic Toxicity LC50 ³ 50% (8) Annually (9) (once in permit term?)

Notes:

1. All parameters listed in table are Standard Monitoring Benchmarks unless otherwise noted.

2. SU = Standard Units

3. NE = None Established

4. The semi-annual monitoring periods are January 1 to June 30 and July 1 to December 31.

5. mg/L = milligrams per liter

6. Sector-specific benchmark

7. Sector H facilities are required to sample copper semi-annually for the life of the Stormwater IGP. Additionally, the

Regulatory Criteria does not apply.

8. The 48-hour Acute Toxicity LC50 value (% Survival) must be greater than 50%.

9. Aquatic Toxicity monitoring is required annually for the first year of the Stormwater IGP.

4.3.3 SAMPLE COLLECTION (Section 4.5.8)

Sampling should be conducted according to the following criteria.

Stormwater Pollution Prevention Plan 17 Town of Greenwich Holly Hill Resource Recovery Facility

Sampling is to be conducted during a storm event generating a stormwater discharge that occurs at least 72 hours after any previous storm event that generated a stormwater discharge. This is referred to as a qualifying event.

Monitoring events are to be separated by at least 30 days.

Grab samples are to be used for all monitoring. Grab samples are to be collected within the first 30 minutes of a storm event discharge.

All samples must be taken during the same storm event, if feasible. Stormwater discharge containing snow or ice melt may be used, but must be noted on the sample reporting form.

For each storm event monitored, the following information is collected.

The date, discharge temperature, time of the start of the discharge, time of sampling at each outfall and magnitude (in inches) of the storm event sampled; and

The duration between the storm event and the end of the previous stormwater discharge event.

The following outline describes the stormwater sample collection and laboratory testing procedures followed for the outfall.

Collect the samples directly from the outfall. Fill the collection containers with stormwater without touching the insides of the containers. Cover the containers when finished.

Label all samples and store samples in a cooler or refrigerator at 4o C.

Prepare a Chain of Custody and transport the samples to the laboratory as soon as possible (less than 24 hours after sampling).

Unless otherwise specified in the Stormwater IGP, all pollutant parameters must be tested according to methods prescribed in 40 CFR 136.

Acute toxicity biomonitoring tests must be conducted according to the procedures specified in Methods for

Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, 5th edition (EPA 821-R-02-012).

When adverse weather conditions prevent stormwater monitoring during the quarter, a substitute sample during the next qualifying storm event will be collected. Documentation of the rationale for no sample collection for the quarter will be included with the SWPP Plan records. 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.

If the facility is located in an area where freezing conditions may occur that prevent runoff from occurring for extended periods, then the stormwater monitoring may be distributed during seasons when precipitation runoff occurs.

4.3.4 RECORDKEEPING AND REPORTING REQUIREMENTS (Section 4.3.2.7.f)

For each stormwater sample taken, the following information is recorded.

Stormwater Pollution Prevention Plan 18 Town of Greenwich

The place, date and time of sampling;

The person(s) collecting the samples;

The dates and times the analyses were initiated;

The person(s) or laboratory who performed the analyses;

The analytical techniques of methods used; and

The results of all required analyses.

A log for recording this data is presented in Appendix F.

After collection of 4 semi-annual samples, if the average of the 4 monitoring values for any parameter does not exceed the benchmark, the monitoring requirements for that parameter have been fulfilled for 2 years. An exemption for sample pH cannot be earned until exemptions for all other parameters are met.

All monitoring data must be submitted electronically using the NetDMR system available at www.epa.gov/netdmr no later than 30 days after the last day of the monitoring period. Copies of the submitted monitoring reports may be kept in Appendix F.

4.4 CORRECTIVE ACTION MEASURES (SECTION 4.6)

WHEN CONDITIONS REQUIRING CORRECTIVE ACTIONS OCCUR OR ARE DETECTED THROUGH INSPECTIONS, MONITORING OR OTHER

MEANS, THE FACILITY WILL TAKE CORRECTIVE ACTIONS TO ENSURE STORMWATER IGP CONDITIONS ARE MET AND POLLUTANT

DISCHARGES ARE MINIMIZED. THE FOLLOWING TRIGGERING CONDITIONS REQUIRE CORRECTIVE ACTION MEASURES (CAMS).

THE average of 4 consecutive monitoring values for any parameter exceeds the benchmark or if fewer than 4 semi-annual samples are collected but a single sample or the sum of samples exceeds the benchmark by more than 4 times that parameter’s threshold.

A spill, leak, release or discharge of non-stormwater not authorized by the Stormwater IGP or another permit.

A required Stormwater Control Measure is not stringent enough for a stormwater discharge to be controlled as necessary such that the receiving water meet applicable water quality standards.

A required Stormwater Control Measure was never designed, installed, implemented or maintained.

Construction or a change in the design, operation or maintenance at a facility that significantly changes the nature or increases the quantity of pollutants discharged.

Color, odor, floating solids, settled solids, suspended solids or foam observed in discharged water during a visual assessment.

When any of the above conditions occur, the Facility must take corrective action measures (CAMs) as follows.

Immediate Actions (within 1-2 days) - If a CAM is triggered, the Facility will immediately take all reasonable

Stormwater Pollution Prevention Plan 19 Town of Greenwich Holly Hill Resource Recovery Facility steps necessary to minimize or prevent the discharge of pollutants until a permanent solution is installed and made operational.

Subsequent Actions (within 14-60 days) - If additional actions are necessary beyond those implemented as immediate measures, the Facility will complete the corrective actions before the next storm event, if possible, and within 14 calendar days from the time of discovery of the corrective action condition. If it is infeasible to complete the corrective action within the 14-day time frame, the Facility will document that and identify a schedule for completing the work which must be done as soon as possible but no longer that 60 days after discovery.

Extension (greater than 60 days) - If the completion of corrective action will exceed the 60-day time frame, the

Facility may take the minimum additional time necessary to complete the action. The Facility will update its

SWPP Plan with the rationale for the extension and a completion date.

Follow-up Sampling - For those corrective action triggering conditions that require follow-up sample, the

Facility has an additional 30 calendar days to collect the follow-up sample. Once sampling results are received, the Facility will report the results by email to DEEP within 30 days.

4.4.1 CAM LEVEL 1: REVIEW SWPP PLAN / STORMWATER CONTROL MEASURES (Section 4.6.2.1)

Review the SWPP Plan and control measures to ensure the effectiveness of the measures and determine if modifications are necessary to meet the Stormwater IGP conditions. After reviewing, the Facility will implement additional measures that would reasonably be expected to address the initial corrective action triggering condition. If it is determined that nothing further needs to be done, it will be documented in the SWPP Plan. The Facility will follow the Subsequent Actions and Follow-up Sampling requirements discussed above.

4.4.2 CAM LEVEL 2: SWPP PLAN REVIEW AND ADDITIONAL STORMWATER CONTROL MEASURES (Section 4.6.2.2)

If after the steps taken for CAM Level 1, subsequent inspections and/or follow-up monitoring data indicated that the triggering condition persists, CAM Level 2 is initiated. The Facility will review the SWPP Plan again and implement additional pollution prevention/good housekeeping Control Measures beyond those already in place. Control measures beyond those reviewed in the original response must be considered. The Facility will follow the Subsequent

Actions and Follow-up Sampling requirements discussed above.

4.4.3 CAM LEVEL 3: SWPP PLAN REVIEW AND ADDITIONAL STORMWATER CONTROL MEASURES (Section 4.6.2.3)

If after the steps taken for CAM Level 2, subsequent inspections and/or follow-up monitoring data indicated that the triggering condition persists, CAM Level 3 is initiated. The Facility will install structural controls and/or treatment controls. The Facility will select controls with pollutant removal efficiencies that are sufficient to prevent or minimize the pollution of stormwater. The Facility will follow the Subsequent Actions, Extension and Follow-up

Sampling requirements discussed above.

4.4.4 WAIVERS (Section 4.6.2.4)

Stormwater Pollution Prevention Plan 20 Town of Greenwich

If the Facility has progressed to CAM Level 3 and structural source and/or stormwater treatment control measures do no resolve a given corrective action triggering condition and if it is found that further actions are infeasible, the

Facility may request a waiver from further corrective action and/or follow-up monitoring. “Infeasible” means not technologically possible or not economically practicable and achievable in light of best industry practices. Waivers may be also requested when the triggering condition is due to run-on from a neighboring source or due to an abnormal event.

4.4.5 DOCUMENTATION IN SWPP PLAN (Section 4.6.5)

Within 24 hours of becoming aware of a CAM-triggering event, the Facility will document the existence of the conditions and maintain the documentation on site. The findings will be summarized in the Annual Report. The following information must be included in the documentation:

Description of the condition or event triggering the need for correction action review and/or CAM response;

Date the condition/triggering event was identified;

Description of immediate actions taken to minimize or prevent the discharge of pollutants; and

A signed and certified statement.

5.0 TRAINING, INSPECTIONS AND RECORDKEEPING

This section of the Plan describes the Training, Inspections and Recordkeeping procedures for the Facility Appendix C contains recordkeeping log forms for inspections and Appendix D contains recordkeeping log forms for training and

Plan revisions. All records of inspections, training and Plan revisions are maintained by the Stormwater Pollution

Prevention Team and may be kept with the Plan.

5.1 TRAINING (Section 4.2.13)

All training will be provided within 90 days of employment and held on an annual basis. Any personnel associated with facility operations or product handling at the facility is required to attend the training.

The training topics include the following items:

Instructions on the contents of this SWPP Plan.

Discussion of the Stormwater Pollution Prevention Team and its responsibilities.

A review of the proper Control Measures to be used by employees on a regular basis, including spill prevention and response; standard housekeeping measures; and materials and waste handling procedures.

A review of the most recent stormwater Comprehensive Site Compliance Evaluation results and any resulting changes to the SWPP components of this Plan.

5.2 INSPECTIONS (Section 4.4)

The Stormwater Pollution Prevention Team is responsible for the entire facility and its proper operation. Facility

Stormwater Pollution Prevention Plan 21 Town of Greenwich Holly Hill Resource Recovery Facility inspections are conducted by at least one member of the Team.

Inspection forms for this Plan have been developed for the facility. The forms are designed to meet the inspection requirements of the Stormwater IGP regulation. A copy of the forms is presented in Appendix C. Records of inspections are maintained by the Stormwater Pollution Prevention Team and may be kept with the Plan. The sections below describe the components of the facility inspections.

5.2.1 ROUTINE INSPECTIONS (Section 4.4.1)

On a monthly basis, at least one member of the Stormwater Pollution Prevention Team or someone designated by it conducts a walk through of the facility. At a minimum, vessel maintenance areas, oil storage areas, material storage areas, vessel storage and the general yard area are inspected to ensure that all equipment, systems and structures are in a satisfactory condition.

5.2.2 STORMWATER VISUAL INSPECTIONS (Section 4.4.2)

Visual inspections of stormwater are conducted quarterly throughout the period of Stormwater IGP coverage. For monitoring purposes, quarters will begin on January 1, April 1, October 1 and December 1. Inspections are conducted during a qualifying rain event. If no qualifying rain event occurs during the quarter, a letter will be entered into the file documenting such. Visual monitoring of stormwater is conducted during the first 30 minutes of the rain event.

The examination documents observations of color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen and other obvious indicators of stormwater pollution. The inspection is documented.

If the visual assessment indicates the Stormwater Control Measures for the facility are inadequate or are not being properly operated and maintained, the Facility will follow the guidance in Section 4.4 of this SWPP Plan.

5.2.3 COMPREHENSIVE INSPECTIONS (Section 4.4.3)

Comprehensive Inspections are conducted every six months at the Facility by one or more persons either on the

Stormwater Pollution Prevention Team or designated by it. All potential sources of pollution identified in Section 2.2 of this Plan are inspected to assure that appropriate Stormwater Control Measures (Section 4.2) are implemented.

Any modification, including the elimination, movement or creation of an exposed area or pollution source, is documented. The SWPP Plan is updated to reflect this information as needed.

The Comprehensive Inspections are conducted, when possible, during a rainfall event. Any deficiencies observed during the evaluation are noted on the form. If the Comprehensive Inspection indicates the Stormwater Control

Measures for the facility are inadequate or are not being properly operated and maintained, the Facility will follow the guidance in Section 4.4 of this SWPP Plan.

Stormwater Pollution Prevention Plan 22 Town of Greenwich

5.3 REPORTING, RECORDKEEPING AND DOCUMENTATION REQUIREMENTS (Sections 4.4.4, 4.7, 4.8)

The Facility must submit an Annual Report electronically by April 15th of each year containing information generated during the past calendar year. The Annual Report must include the following information.

Summary of monitoring data;

Summary of past year’s routine facility inspections;

Summary of past year’s quarterly visual assessments;

A summary of the past year’s corrective action documentation and any required CAM documentation;

Certification

In addition to the reporting requirements stipulated above, the Facility is also subject to standard permit reporting provisions.

Immediate reporting - The Facility must report any spill, leak, release or discharge of non-stormwater not authorized by this IGP.

24-hour reporting - The Facility must report any condition which may endanger human health or the environment.

5-day follow-up reporting to the 24-hour reporting - A written submission must also be provided within 5 days of the time the Facility becomes aware of the circumstances.

Planned changes - The Facility must give notice to DEEP within 30 days of any planned physical alterations and/or additions to the permitted facility that qualify the facility as a new source or that could significantly change the nature or significantly increase the quantity of pollutants discharged.

Anticipated noncompliance - The Facility must give advance notice to DEEP of any planned changes in the permitted facility or activity which the facility anticipates will result in noncompliance with permit requirements.

Transfer of ownership and/or operation - The entity acquiring the facility must submit a complete and accurate

Registration in accordance with the requirements of the Stormwater IGP, and the original permittee (the first owner or operator) must submit a Notice of Termination.

Compliance schedules - Reports of compliance and/or noncompliance with or any progress reports on, interim and final requirements contained in any compliance schedule of this permit must be submitted no later than 14 days following each schedule date.

Other noncompliance - Report all instances of noncompliance not reported in the monitoring report, compliance schedule report or 24-hour report at the time monitoring reports are submitted.

Other information - Promptly submit facts or information if Facility becomes aware of failure to submit relevant facts in the Registration or any report.

The Facility is required to keep the following inspection, monitoring and certification records complete and up-to-date and demonstrate full compliance with the conditions of this permit.

• A copy of the Registration and supporting documents submitted to DEEP along with any correspondence exchanged between the facility and DEEP specific to coverage under the Stormwater IGP.

Stormwater Pollution Prevention Plan 23 Town of Greenwich Holly Hill Resource Recovery Facility

• A copy of the Authorization Letter to discharge from DEEP assigning a permit number.

• A copy of this permit (an electronic copy easily available to SWPP Plan personnel is also acceptable). An electronic copy of the Stormwater IGP may be found at the following link:

https://portal.ct.gov/deep/water-regulating-and-discharges/stormwater/industrial-stormwater-gp.

• Documentation of maintenance and repairs of control measures, including the date(s) of regular maintenance, date(s) of discovery of areas in need of repair/replacement and for repairs, date(s) that the control measure(s) returned to full function and the justification for any extended maintenance/repair schedules.

• All inspection reports, including the routine facility inspection reports and the quarterly visual assessment reports.

• Description of any deviations from monitoring and inspections schedules and the reason for the deviation (e.g., adverse weather or it was impracticable to collect samples within the first 30 minutes of a measurable storm event).

• Description of any corrective action taken at this facility, including triggering event and dates when problems were discovered and modifications occurred.

This SWPP Plan and all training, inspection, recordkeeping and testing records associated with it are maintained for a minimum of 5 years following the expiration of the Stormwater IGP. Records are signed by an appropriate supervisor, where applicable. Modifications to this Plan are recorded in the Revisions Log in Appendix D.

6.0 PLAN REVIEW AND AMENDMENT (Section 4.3.5)

Osprey recommends that this Plan be reviewed at least annually by the Stormwater Pollution Prevention Team to verify that it represents current facility conditions and complies with current regulations. During this review, The Facility should check with a qualified environmental consultant or the CT DEEP to verify that the most current governing regulations are incorporated.

The Facility will amend this Plan within 120 days whenever the facility experiences any of the following conditions:

a substantial change which has a significant effect on the discharge, or potential for discharge, of pollutants in stormwater from the facility;

an inspection, investigation or monitoring event which shows that the Plan is not effectively controlling or eliminating pollutants in stormwater discharges;

a failure of the Plan to ensure or adequately protect against pollution of the waters of the State;

a request by the Commissioner of the CT DEEP to modify the Stormwater Pollution Prevention Plan; or a notification that they are subject to requirements because the receiving water to which it discharges stormwater has been designated as impaired under Section 303(d) of the Clean Water Act and…