Environmental Policy

Atlas Metal & Iron Corporation is dedicated to responsible and environmentally safe operating procedures and practices through compliance with all applicable local, state, and federal environmental laws and regulations. Atlas Metal & Iron Corporation's commitment to maintaining an environmentally sound workplace is demonstrated by our adoption of industry-developed comprehensive environmental operating guidelines. Atlas Metal & Iron Corp supports Design for Recycling TM - a national policy to promote the design and manufacture of goods that, at the end of their useful life, can be recycled safely and efficiently.

Chapter 1

INTRODUCTION

1.0 BACKGROUND

The scrap recycling industry is a vital and well established part of this country's effort to reclaim valuable secondary materials for reuse into new products, conserve natural resources, and make better use of diminishing landfill capacity. For over a century, the scrap recycling industry has provided a valuable service to consumers, manufacturers, and the government. The industry handles over 100 million tons of recyclable materials that would otherwise become part of the solid waste stream and, of this, returns to commerce well over 90 million tons. Many of the post-consumer materials handled by the industry are at the end of their useful life, and, as a result, it becomes the responsibility of the scrap recycling industry to deal with the problems created during their manufacture, such as the use of hazardous constituents and non recyclable materials in these products. This document is meant to demonstrate the commitment of our company and of the scrap recycling industry in establishing responsible and environmentally safe operating procedures and practices.

Recyclable materials are those materials that were diverted or removed from the potential solid waste stream (and are thus not included as part of it) and from subsequent treatment or disposal in incinerators or landfills, and, instead were recycled into new products. Scrap recyclers manufacture and sell these products for beneficial reuse, conserving impressive amounts of energy in the process. For example, recycled aluminum scrap saves the nation 95% of the energy that would have been needed to make the same amount of new aluminum from virgin ore. Beyond the energy savings, there are equally impressive environmental savings as well, including major reductions in air emissions, water pollution, water usage, and mining waste generation.

1.1 OVERVIEW OF THE SCRAP RECYCLING INDUSTRY

Scrap recyclers accomplish the goal of recycling only if three steps occur: collection, processing, and reuse. Scrap processors commonly purchase automobiles, appliances, railroad equipment, demolition materials from buildings and bridges, newspapers, beverage cans, and packaging materials, as well as pieces produced from cutting and fabricating in durable goods manufacturing.

The next step in the recycling process is preparation of the recyclables so that they may be used to make new products. The scrap processor has a major capital investment in heavy machinery designed to sort, shear, bale, shred, chop, or otherwise transform the inbound recyclables to produce a uniform product that meets strict specifications.

The final step in the recycling process is finding a use for the processed materials. After processing, the product is shipped to an end user such as a steel mill, foundry, ingot maker, nonferrous metals smelter, glass manufacturer, or paper mill to serve as a raw material in a manufacturing process. These scrap materials are purchased by the manufacturer, the price being responsive to the demand for the material. The markets for scrap materials are very volatile, subject to sudden price changes resulting from such factors as availability and supply. These factors distinguish recycling as a complicated market-sensitive industry from the solid waste management industry.

Scrap recycling facilities are manufacturers, who from a fixed location, utilize machinery and equipment for processing recyclables - including ferrous and nonferrous metals, paper, plastic, and glass - into prepared grades ready for consumption as a raw material. It is not until the recyclables reach the scrap recycling facility from the auto dismantler, metal fabricators, private citizen, or other source that the manufacturing process begins, producing a resource of recycled feedstock for direct consumption by steel mills, foundries, smelters, paper mills, and refiners.

Atlas Metal & Iron Corp. operates several pieces of processing equipment and some of those are:

1.2 PURPOSE OF THE GUIDELINES

This document is designed to describe Atlas Metal & Iron Corp's environmentally sound operating procedures used in our scrap processing operations. This document has been prepared to demonstrate our commitment to environmentally responsible recycling. It provides site management practices designed to minimize, or where possible eliminate, potential adverse environmental effects. As changes become necessary, they will be incorporated.

Chapter 2

ENVIRONMENTAL OVERVIEW

2.0 INTRODUCTION

This chapter provides an introduction to the parameters governing environmental compliance. A necessary first step is a discussion of the potential pathways of environmental contamination, including a description of environmental media potentially affected - air, soil, and water (ground and surface). The objective of this section is to provide a clear understanding of the regulatory requirements promulgated by the U.S. Environmental Protection Agency (EPA) and other state and local regulatory agencies for the scrap processing and recycling industry.

2.1 NEED FOR ENVIRONMENTAL PROTECTION

The issues that face us all are maintaining the air we breathe, the water we drink, and the soil we live and grow on so that they are suitable to sustain an acceptable quality of life. The uncontrolled discharge of some materials above certain levels presents a threat to human health and the environment. While there is little we can do to prevent natural occurrences, there is a great deal we can do to prevent or reduce the impact of those events caused by man.

AIR

The air we breathe is composed of 78% nitrogen, 21% oxygen, and residual amounts of carbon dioxide, water vapor, and other gases. All of these exist in a simple physical mixture. The oxygen and carbon dioxide present in the air chemically affect all forms of life through photosynthesis and respiration. An imbalance in atmospheric conditions due to the presence of contaminants can cause harm o the environment. There air contaminants, or pollutants, may include dust, fumes, gases, mists, odors, smoke, and vapors. Pollutants can be of a duration or of characteristics that can be injurious to human, plant, or animal life, as well as to property. Their presence at certain levels can also interfere unreasonably with the comfortable enjoyment of life. The sources of the air pollutants mentioned above are many and include natural occurrences; industrial, transportation, and agricultural activities; commercial/domestic heat and power; and municipal activities.

Natural sources of air pollution include pollen, windstorm dusts, smoke, as from fires, and naturally occurring ozone. Industrial sources may include ventilation products from local exhaust systems; process waste discharges; and heat and power from combustion processes. Transportation sources include motor vehicles, rail-mounted vehicles, airplanes, and vessels. Sources associated with agricultural activities include insecticidal and pesticidal dusting and spraying and the burning of vegetation. Commercial and domestic heat and power sources include gas-, oil-, and coal-fired furnaces. Municipal sources include refuse disposal, liquid waste disposal, road and street repair operations, and fuel-fired combustion operations.

When air pollutants or contaminants are in the air, an imbalance in the atmosphere is created, thus affecting animal and human life. As humans and animals breathe, they inhale the materials that are in the air, potentially initiating or aggravating a variety of respiratory problems. These pollutants may also get into the food chain because airborne materials have a tendency to settle on vegetation, thus potentially impacting humans and animals who may eat the contaminated vegetation. Air pollutants may also adversely affect property. When these pollutants settle, they land on buildings , equipment, vehicles, and other property, cause discoloration, corrosion, and soiling. Air pollution may also impair visibility.

Therefore, since air quality is important to us, standards and guidelines have been developed by the government in the form of regulations to control air pollutants. These regulations include restriction on the sources of pollution on community air, limits on the amounts of specific pollutants to be present in the air, and limits on the amount of impurities in raw materials used for processing.

SOIL

Soil covers most of the land surface. Soils have layers, more or less parallel to the surface and differing from those above and below in one or more properties, such as color, texture, structure, consistency, porosity, thickness, and reaction. The succession of the layers is called the soil profile.

Soil erosion is a physical process by which soil material is weathered away and carried downgrade by water or moved about by wind. It is in this way that soil can contaminate both water and air. Soil conservation is the practice or arresting and minimizing accelerated soil deterioration. Its importance has grown due to increased cultivation of soils for agricultural production, deforestation and forest cutting, grazing of natural ranges, and other disturbances of the natural cover and position of the soil.

Contaminated soil, just like contaminated air, can adversely impact the food chain. If soil that is used to grow food is contaminated through industrial processes or through air or water pollution, the contaminants may be transferred to the food animals and humans eat. In addition, soil structures used to contain water may impart contamination to the water they are containing, transferring potential contamination to the fish and animals who come in contact with the water. Thus the food chain is greatly impacted by the condition of the soil.

WATER

Water is found in surface water bodies and in groundwater. Surface water bodies include lakes, marshes, streams, glaciers, and reservoirs. In the broadest sense, surface water is all the water on the surface of the Earth and thus includes the oceans. Streams supply most of the water needs of the United States. Lakes, swamps, ponds, marshes, and reservoirs represent stored stream flow. The majority of the water used in public water supplies is returned to the environment. However, pollution prevents reuse of part of the return flow.

Groundwater includes the water in the root zone of the soil. Areas where sufficient quantities of groundwater exist to supply wells or springs are called aquifers. Aquifers store water in the spaces between particles of sand, gravel, soil, and rock.

Water pollution is generally defined as the presence of impurities in water at a quantity and of a nature that impairs the use of the water for a stated purpose. Sources of water pollution include industrial waste streams, storm water runoff, irrigation flow, and natural disasters such as earthquakes and hurricanes. Thus, regulatory requirements designed to control surface water contamination are usually base on whether the receiving water is used as a source of drinking water, recreation, or for another purpose. Groundwater contamination can originate on the surface of the ground as a result of a spill, in the soils above the water table, or in the soil below the water table. As the contaminates move through different layers of soil dilution, biological decay, filtration, and other processes may occur, thus lessening the eventual impact of the substance once it reaches the groundwater. However, in comparison with surface waters, groundwater tends to move more slowly and with little turbulence. Therefore, once contamination reaches groundwater, little dilution or dispersion occurs.

2.2 FEDERAL ENVIRONMENTAL STATUTES OF CONCERN

Certain Federal statutes governing the above referenced forms of contamination may include, but are not limited to: