Running a mining operation or ready-mix plant is tough enough when you have orders flying in, drivers that are late (or don’t show), and customers not paying their invoices. However, as one of the most scrutinized industries out there for environmental regulations, you have not only local, state and federal agencies breathing down your neck for air, wastewater, and spill (SPCC), but also the ever-present environmental groups or NGOs (non-governmental organizations). Let’s take a deep breath and focus on one thing today, industrial stormwater permits.
In California, the Industrial General Permit (IGP) covers mining, concrete ready-mix plants, and asphalt batch plants, and in Washington that might be the Sand & Gravel Permit or Washington Industrial Stormwater General Permit (ISGP). Depending on your state, there may be a specific mining sector permit, like Colorado, which has a combined stormwater and wastewater general permit. However, regardless of the state permit you are operating under, there are some parameters that prove to be problematic for construction and industrial material facilities. As sites in this sector tend to be large (sometimes hundreds of acres) and unpaved, there is a lot of Total Suspended Solids (TSS) showing up in water samples. With high TSS, and the underlying rock, gravel, and dirt containing naturally occurring metals, such as iron (Fe) and aluminum (Al), there are often exceedances of benchmarks or numeric action levels (NALs) for parameters such as iron. Iron exceedances are also common due to that “boneyard” out back, because your owner or plant manager never wants to throw anything away.
There are some typical Best Management Practices (BMPs) or Stormwater Control Measures (SCMs) that are implemented in the construction and industrial materials industry. For instance, using swales to direct runoff to retention ponds can limit the amount being discharged, thus reducing sampling frequency, and allow longer periods of time for sediment (TSS) to settle out. As mentioned earlier, iron and aluminum are often associated with the underlying sediment, so decreasing Total Suspended Solids in discharges often correlates to a drop in iron and aluminum concentrations in water quality samples. If a pump and treat type of system are needed, the use of a flocculent to increase settling of solids can have a similar impact as swales and ponds.
Due to the risk of lawsuits and regulatory enforcement, environmental health and safety (EHS) staff at mines, ready-mix facilities, and sand & gravel plants should be vigilant about track out (remember, trucks coming from unpaved sites with rain make a lot of mud) as that can often bring about unwanted attention. Rumble strips or plates are a cheap, common contractor style BMP. However, they need to be cleaned regularly and are not the most effective. A wheel wash is sometimes necessary for the high profile or especially muddy industrial sites. As with other facilities dealing with TSS issues, if you have storm drain inlets, a good insert can do wonders at reducing Total Suspended Solids concentrations in water discharges. However, remember that any BMP is only effective if properly maintained, so while you “never have any money”, don’t skimp on replacing witches’ hat insert or more permanent inserts. One advantage that you have is that the construction materials industry has easy access to heavy equipment and concrete, so ponds can easily be dug and check dams with your own rip-rap can be built. A lot of DIY BMPs are some of the most effective ones, but you just need a little guidance and know-how.
Don’t think that once the BMPs are in that you have smooth sailing. Maintenance matters and those pesky inspections you need to do are not just meant to build a better door jam (AKA three-ring binder). Instead those monthly or quarterly inspections should be easy to do, hey what do you know software makes it a breeze via your phone, but also communicate out deficiencies and repairs needed. Those three-ring binders of inspection forms, by the way, are a thing of the past and for an EHS manager or company owner, a potential liability if they disappear. With the attention given to construction material sites and ready-mix concrete plants, you don’t want to fight in court without the full records (you know the five years worth you were supposed to have). Instead of making it harder for the plant manager, as if he (and it usually is a he), doesn’t have enough to worry about without trying to track down a form to fill out at the end of the month, take to the office, scan, send to the EHS team, and tell the rest of the staff to replace the storm drain insert….takes out his phone, answers a few questions and voila an email is sent to the staff automatically with the photo of the problem and automatically a record is created. Sound to easy to be true? Wrong!
We get it that it is “just dirt” and the boneyard is “important” for that part you might need someday ten years from now, but unfortunately in many litigious environments, like California, that doesn’t mean much when you are dealing with exceedances. Therefore, as an EHS professional in the construction and industrial materials industry, whether you have a ready-mix plant or mine, you need to be on top of your structural BMP game with check dams in your swales, a vegetated retention pond, or a good flocculent in your treatment system. The name of the game is often slow the flow and let solids (TSS) settle out to reduce naturally occurring metals. Also, know you will have inspectors and environmental groups knocking on your door, so keep the site maps up to date, yes even in a dynamic environment. Oh, and don’t ever just pencil-whip your inspections.
Mapistry is the go-to solution to industrial permit headaches for savvy companies in the Construction & Industrial Materials Industry from training staff on the basics of BMPs to designing effective swales and treatment systems to state or country-wide compliance software that cuts staff time, reduces the risk of lawsuits, and ensures the EHS department can sleep at night.