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: (407)893-3317

40. DEP Tallahassee Contacts • Vince Seibold - Industrial Wastewater Administrator (850)921-9387 • Sherry Allick - CBP Coordinator (850)921-9448

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.