Compliance Requirements for Concrete Batch Plants

1
Compliance Requirements for Concrete Batch Plants

• Gene Elliott/Wanda Parker-Garvin
• DEP Water Facilities

2
Why do we care about Concrete Batch Plants (CBP)?

• Primary concern is contaminated storm water and
  interior truck mixer drum wash out water
• Hydrocarbons from refueling and truck
  undercarriage washing

3
Why do we care about Storm Water?

• In General SW can contain high levels of several
  contaminants
• sediments, nutrients, heavy metals,
• pathogens, toxins, oxygen demand
• For CBP pollutants of concern are pH,
• suspended solids (TSS), petroleum hydrocarbons
  (TRPH), specific conductance

4
SW can impair water quality

• Threaten designated use
• alter or destroy habitat
• imbalance flora and fauna
• pollution tolerant species
• overload self cleaning mechanism (assimilative
  capacity)

5
Wow! It does all that

• Urban Runoff was a major cause of impairment in
  45 of impaired estuaries, also impairment to
  streams, lakes
• Second only to Industrial Discharges
• greater than municipal point sources (domestic
  sewer plants)
• leading cause of impairment to oceans

6
So What Do We Do Regarding CBP?

• Control/Treat Storm water with Wet Detention or
  Retention Ponds.
• Require complete retention for process wastewater
  from interior truck mixer drum wash out (25 year
  24 hour storm)
• Use of IBMP or WSMP (Best Management Practices,
  BMPs and pollution prevention)

7
Rule Designates Two Types of Wastewater's
(Contaminated Storm Water Process Wastewater)

• Type I Wastewater Includes
• Contact storm water (Exposure areas)
• Runoff from aggregate piles (process)
• Washdown water not including interior
• mixer drum washout (process)

8
Type I Wastewater

• Washdown water
• Water sprayed for dust control (process)
• Does not include equipment washing or
• truck undercarriage washing (process)
• Includes washing of exterior of mixer
• trucks and mixer truck chutes, or other
• washing operations (slump racks, etc)

9
Type II Wastewater

• Wastewater generated from the washout of the
  interior of a concrete truck mixer drum and any
  water that comes into contact with this
  wastewater
• Excludes Type II wastewater used to spray
  aggregate piles

10
GP Coverage for Two Types of CBP Systems

• Existing In operation before May 1996
• Includes Un-permitted Existing Systems
• Un-permitted existing systems are covered under
  the voluntary consent order
• New In operation after May 1996
• Governing rule is Chapter 62-621 Generic
  Permits, May 1997 for CBP

11
What is the basic difference between New vs.
Existing CBP

• New - Basically the storm water treatment
  requirements for wet detention/retention systems
  are more stringent
• New - Must account for non contact storm water.
  Non-contact storm water includes those areas on
  the site that do not have exposure to industrial
  pollutants (roof runoff, employee parking areas,
  etc).

12
Existing Systems

• Existing systems may or may not be permitted at
  this time based on a specified compliance
  schedule in the voluntary consent order
• Un-permitted existing systems under a voluntary
  consent order must meet interim Best Management
  Practices (IBMP), to address Type I and Type II
  wastewater's until a permit can be obtained.

13
What is an IBMP?

• A plan that must be prepared for each existing
  facility under the consent order.
• Required to be implemented during the period of
  coverage under the consent order
• Not the same as a wastewater and storm water
  management plan (WSMP), which only applies to new
  systems

14
What must the IBMP Contain?

• Schedules of activities
• prohibitions of practices
• maintenance procedures
• sound management practices to prevent or reduce
  the pollution of waters of the State
• treatment requirements
• operating procedures and practices to control
  plant site runoff

15
IBMP Requirements Contd.

• Control of spillage or leaks
• Drainage from raw material storage and waste
  disposal areas
• Describe which practices will be used to reduce
  the pollutants in storm water discharges
• Must be made available to the Department upon
  request

16
Compliance issues for Existing Un-permitted
Systems

• DEP is now inspecting these facilities
• Many facilities have not yet developed an IBMP
  plan
• Many are not employing IBMP as required by the
  Consent Order
• May apply for an Individual Permit

17
Compliance issues for Existing Un-permitted
Systems

• Failure to have an IBMP or follow the IBMP can
  result in enforcement
• Improper handling of truck washwater
• Improper handling of Type II wastewater
• Improper control of runoff from Type I area of
  the site (exposure areas).
• Failure to maintain existing systems/ponds

18
Compliance issues for Existing Un-permitted
Systems

• Failure to maintain existing Type II systems
• Improper solids disposal and dewatering of solids

19
Concrete Products Plants

• Was not evaluated during the Rule development for
  this GP
• Must obtain an indivgual IW permit
• May find additives not common to the Batching
  Industry
• May have sampling included
• May use similar design standards

20
Compliance issues for Existing/New Permitted
Systems

• Failure to construct the treatment systems in
  accordance with the permit requirements
• Must have a copy of the permit on-site
• Must has a copy of the as-builts (engineering
  drawings) on-site
• Must have the Wastewater and Storm Water
  Management Plan (WSMP) on-site

21
What are WSMPs

• WSMP similar to the IBMP but more formally
  identifies storm water pollution prevention and
  BMPs
• Pollution prevention includes things like clean
  up of petroleum/hydraulic fluid spills and other
  spills. Use of low volume wash waters for wash
  down and reuse (there have been some innovative
  designs).

22
What are WSMPs

• Pollution prevention is required to prevent the
  discharge of contaminates from storm water
  related events
• BMPs include things like implementing practices
  to ensure long term operation and maintenance
  procedures for storm water and type II systems

23
What are WSMPs

• BMPs include practices for beneficial reuse of
  Type I and Type II solids and wastewater
• BMPs include proper procedures for solids disposal

24
More on Compliance issues for Existing/New
Permitted Systems

• Improper handling of truck washwater and other
  wash waters
• Improper dewatering of Type II solids
• Clogging of outlet structures in the storm water
  ponds
• Failure to clean sediment pits

25
Compliance issues for Existing/New Permitted
Systems

• Failure to scarify retention ponds on a regular
  basis to prevent clogging from fine particulates
• Spills as a result of cleaning sediment pits
• Spills as a result of cleaning Type II systems
• Failure to address erosion control in storm water
  ponds

26
Compliance issues for Existing/New Permitted
Systems

• Failure to clean out solids from storm water
  ponds
• Failure to submit completion of construction and
  record drawing notification forms
• Lack of training of on-site personnel regarding
  WSMPs and CBP permit requirements

27
Compliance issues for Existing/New Permitted
Systems

• DEP can take enforcement when a facility is out
  of compliance. This can include collecting
  samples etc. to ensure that BMPs, IBMPs, WSMPs,
  and systems were adequately designed.
• DEP inspects every facility annually

28
Compliance issues for Existing/New Permitted
Systems

• Although the facility is not required to sample.
  The facility must meet applicable ground and
  surface water quality standards
• Main pollutants of concern include pH,
  turbidity, TSS (suspended solids), TRPH
  (petroleum hydrocarbons), and specific conductance

29
What are Water Quality Violations?

• Florida Administrative Code Rule 62-302
  classifies surface water bodies according to
  their designated use
• Most surface waters (like the St. Johns) are
  Class III-Swimmable/Fishable
• Concentrations of various parameters are listed
  that support each designation

30
What are Water Quality Violations?

• FAC Rule 62-520, 62-522 identifies ground water
  bodies. Must meet primary and secondary drinking
  water standards at the zone of discharge.
  Standards are contained in Rule 62-550.
• Discharges in excess of water quality standards
  are considered violations
• Also a general prohibition against toxic
  substances in toxic amounts

31
What is the good news for the CBP Industry?

• With simple good house keeping, both existing
  unpermitted and new/existing permitted systems
  can reliably meet DEP requirements (CO and CBP
  permit)

32
What is the good news for the CBP Industry?

• No effluent or ground water monitoring is
  required (except during pond dewatering or
  cleaning), or if DEP observes a potential water
  quality violation
• Your SIC code regarding NPDES storm water
  permitting/process wastewater's is already
  addressed by the generic permit. Therefore no
  USEPA MSGP required.

33
What is the good news for the CBP Industry?

• All other industrial facilities do not have the
  benefit of having the generic permit (e.g.,
  precasting operations, ship yards, lumber yards,
  various other industry sectors) available to them
  at this time.

34
What is the good news for the CBP Industry?

• These other industries will likely be facing many
  non-compliance issues regarding storm water
  related discharges under the USEPA MSGP as well
  as violations of water quality standards

35
What is the good news for the CBP Industry?

• DEP received the USEPA storm water permitting
  authority MS4, industrial, and federal facilities
  (May or October 2000?).

36
What is the good news for the CBP Industry?

• DEP will be inspecting 10 of the multi sector
  general permits (3000) within 10 years. About 20
  Individual SW permits.
• We already know many will be out of compliance
  and require individual permits, enforcement
  action, sampling, etc.

37
What is the good news for the CBP Industry?

• The ready mix concrete industry is ahead of the
  game in regard to this matter!

38
Resources Available

• EPA Office of Water Web page has
• Storm water BMP for industrial facilities
• Other storm water web links
• DEP has a web site www.dep.state.fl.us
• Rules and regulations for Water Resource
• Management Program, etc.
• Our office is always available for assistance

39
Central Florida DEP Contacts

• Christianne Ferraro - Water Facilities
  Administrator
• Ali Kazi - Industrial Wastewater Supervisor
• Gene Elliott - Permitting Engineer
• Wanda Parker-Garvin - Permitting Engineer
• Phone Number [phone]

40
DEP Tallahassee Contacts

• Vince Seibold - Industrial Wastewater
  Administrator [phone]
• Sherry Allick - CBP Coordinator [phone]

41
Additional Note

• Talk to your County Environmental Rep.
• The GP helps the Industry and the Department
  protect the environment together.
• Counties have their own rules which are
  independent of the State DEP. Facilities have to
  be square with both.