Compliance Requirements for Concrete Batch Plants

Report
Industrial Wastewater
Requirements for Concrete
Batch Plants
Yanisa Angulo and Ilia Balcom
Industrial Wastewater Program
DEP Southwest District
SWD IW Jurisdiction
Citrus, Desoto, Hardee, Hernando, Hillsborough,
Manatee, Pasco, Pinellas, Polk, Sarasota, Sumter, and
west Marion County
Why do we care about Concrete
Batch Plants (CBPs)?
Primary concern is contaminated storm
water and interior truck mixer drum washout water.
Why do we care about Storm Water?
 In general, storm water
can contain high levels
of contaminants.
*sediments, nutrients, heavy metals,
pathogens, toxins, oxygen demand
 For CBP pollutants of concern are: pH,
suspended solids (TSS), petroleum
hydrocarbons (TRPH) and specific conductance.
Two “Types” of Wastewater
(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)
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.)
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 reclaimed Type II wastewater
used to spray aggregate piles.
Permit Coverage
Rule 62-621.300(3)(a), F.A.C.
 Permit coverage is under Chapter 62-621.300(3)(a),
F.A.C., effective May 1997.
 http://www.dep.state.fl.us/water/wastewater/iw/docs/6
2-621.300_3a.pdf
 Need to meet the permit criteria. Coverage is for 5
years.
 An application of renewal of coverage is required to
be submitted 180 days prior expiration of the current
permit coverage.
Two Types of CBP Systems
 Existing:
In operation before May 1996
Includes Unpermitted Existing Systems
 Unpermitted existing systems were covered
under the voluntary consent order that required
to obtain permit coverage after construction of
system was completed.
 New: In operation after May 1996
 Currently there are 137 permitted CBPs in the
SWD
The difference in requirements
between New and 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, parking areas,
etc).
Requirements of a Permit Application
 Notice of Intent to Use Generic Permit for
Discharges from Concrete Batch Plants,
DEP Form 62-621.300(3)(b)
 $500 Application Fee
 Engineering Report signed and sealed by a
Professional Engineer registered in Florida
 http://www.dep.state.fl.us/water/wastewater
/forms.htm
What Does CBP GP Require?
 Retain Type II wastewater and runoff from Type
II area up to 25-year/24-hour storm.
 Control/Treat Type I Wastewater and Storm
water with Wet Detention or Dry Retention
Ponds.
 Implementation of Wastewater and Storm water
Management Practices (WSMP).
Engineering Report Includes
Description of Type I, Type II, and non-contact
stormwater management systems and how they
operate.
 Description of how solids are handled, used or disposed
of.
 Description of close-loop vehicle/equipment wash
facility, if applicable.
 Site plan indicating existing and proposed wastewater
and stormwater management systems, drainage basins,
direction of flow, and discharge points, receiving waters,
pervious and impervious areas.

Engineering Report Includes (Cont.)
 Design Criteria:
Calculation of designed daily Type I and Type
II flow,
stormwater runoff calculations,
Design stormwater an sources of data
Stage/storage calculations
Percolation rate determination
Paving, Grading, Drainage Plan
Type II System
Type II System Design Requirements – (New
and Existing Facilities)
Impermeable containment
 Contain produced Type II wastewater plus direct rainfall into
and storm water runoff from Type II area, resulting from 25yr, 24-hr storm events
 No direct discharge from the Type II system to groundwater
or surface waters
 Runoff from ribboning area should be directed to the type II
System
 Overflow from the Type II system shall discharge to a Type I
system or an emergency holding pond only as a result of
rainfall in excess of the 25-yr, 24-hr storm event.

Ribboning
Type I System
Type I System Design Requirements –
(Existing Facilities)
 Wet detention
Sediment trap(s), mostly constructed of concrete
Offline wet detention to treat first ½ inch of runoff from
Type I area plus produced Type I wastewater
Drawdown (control) device: orifice, v- or square-notch
weir
Overflow device: standpipe or weir
One-half of the treatment volume is recovered within
the first 48-60 hours following a rain event
Type I System Design Requirements
(Cont.)

Dry Retention
The retention system must retain produced Type I
wastewater plus one of the following:
– runoff from 10-year, 24-hr storm
– runoff from the first 1-inch of rainfall
– the first ½ inch of runoff
Demonstrate recovery of system storage capacity
within 72 hrs following any runoff producing event
through percolation to ground water and evaporation
Type I System Design Requirements
(New Facilities)
 Wet detention-Off line wet detention
Sediment trap(s)
Offline wet detention to treat first ½ inch of runoff from
Type I area
One-half of the treatment volume is recovered within the
first 48-60 hours following a rain event
Drawdown(control)device: orifice, v-or square-notch weir
Overflow device: standpipe or weir
Type I System Design Requirements–
New Facilities (Cont.)
 Final Wet Detention
One-half of the treatment volume is recovered within
the first 48-60 hours following a rain event
Detain and treat the discharge from the off-line
system and runoff from the type I area and noncontact storm water area of the site
Drawdown (control) device: orifice, v-or squarenotch weir
Overflow device: standpipe of weir
Type I System Design Requirements –
New Facilities (Cont.)
 Dry Retention
The retention system must retain run off from the
Type I area of the site, including all produced Type I
wastewater and runoff from non-contact area
resulting from 10-year, 24-hr storm
Demonstrate recovery through percolation to ground
water and evaporation
Type I System Design Review – New
Facilities (Cont.)
 Pre vs. Post-development
Post-development rate of discharge of storm water
runoff must not exceed pre-development rate of
discharge for
– A 25-yr, 24-hr storm event or
– A 100-yr, 24-hr storm event for a closed drainage
basin
Wastewater and Storm Water
Management Plan (WSMP)
 WSMP identifies storm water pollution
prevention and Best Management Practices
(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).
Wastewater and Storm Water
Management Plan (WSMP) – Cont.
 Pollution prevention is required to prevent the
discharge of contaminants from storm water
related events.
 BMPs include on-site procedures and practices
implemented to ensure long term operation and
maintenance for storm water and Type II
systems.
Wastewater and Storm Water
Management Plan (WSMP) – Cont.
 BMPs include practices for beneficial reuse of
Type I and Type II solids and wastewater.
 BMPs include proper procedures for solids
disposal.
 The WSMP specifies how often Type I and Type
II systems must be inspected, and inspections
shall be documented on the WSMP.
 BMPs should address ribboning practices,
including rain events
Sweeping Requirement

Facilities shall prevent or minimize the discharge of spilled
cement, aggregate (including sand or gravel), kiln dust, fly ash,
settled dust and other significant materials in stormwater from
paved portions of the site that are exposed to stormwater.
Measures used to minimize the presence of these materials
may include regular sweeping, or other equivalent measures.
The plan element shall indicate the frequency of sweeping or
other measures. The frequency shall be determined based
upon consideration of the amount of industrial activity occurring
in the area and frequency of precipitation, but shall not be less
than once per week when cement, aggregate, kiln dust or fly
ash are being handled or otherwise processed in the area.
Compliance Evaluation Inspections
 Inspections conducted on an annual basis.
 Inspectors evaluate compliance with permit
requirements, including record keeping and
operation and maintenance.
 DEP is required to conduct unannounced
inspections.
 Inspections can also be initiated by a complaint.
Compliance issues for Existing/New
Permitted Systems
 General
Failure to apply for renewal of permit coverage as
required (180 days prior expiration).
Failure to submit abandonment plant prior to closure
of a facility and inactivation of a permit
Failure to construct the treatment systems in
accordance with the permit requirements or as
designed.
Compliance issues for Existing/New
Permitted Systems (cont.)
 Record Keeping Issues:
Failure to have a copy of the permit on-site.
Failure to have a copy of the “as-builts” (engineering
drawings) on-site.
Failure to develop a Wastewater and Storm Water
Management Plan (WSMP) as required. Or, if
developed, WSMP was not on-site, or not updated.
Failure to implement WSMP.
Compliance issues for Existing/New
Permitted Systems (cont.)
 Recordkeeping Issues (Cont.)
Failure to conduct inspections required by the
WSMP. If conducted, failure to properly document
them (complete checklists).
Lack of training of on-site personnel regarding
WSMPs and CBP permit requirements.
Failure to submit completion of construction and
record drawing notification forms.
Compliance issues for Existing/New
Permitted Systems (cont.)
 Type II system Issues:
Improper handling of truck wash water and other
wash waters.
Improper dewatering of Type II solids.
Spills as a result of cleaning sediment pits.
Spills as a result of cleaning Type II systems.
Unauthorized overflows (discharges) from the Type
II system caused by lack of maintenance.
Co-mingling of Type II and Type I wastewater
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
 Type I System Issues:
Failure to clean sediment pits.
Failure to clean out solids from storm water ponds.
Clogging of outlet structures in the storm water
ponds.
Failure to address erosion control in storm water
ponds.
Excessive vegetation that affects the pond’s
performance and hinders inspection of berms.
Unpermitted discharges due to loss of capacity or
breached berms.
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
Compliance issues for Existing/New
Permitted Systems (cont.)
 Although a CBP operating under the Generic Permit
is
not required to sample, the facility must meet applicable
ground and surface water quality standards. If for some
reason there isn’t reasonable assurance that the facility
can meet standards, samples may be required to ensure
that BMPs, WSMPs, and systems were adequately
designed. Main pollutants of concern include: pH,
turbidity, TSS (suspended solids), TRPH (petroleum
hydrocarbons), and specific conductance.
Potential Penalties associated with
violations of the Generic Permit
The Department has the statutory authority to impose fines
for up to $10,000 per day.
 Under the Environmental Litigation Reform Act, the following
amounts apply to specific violations:

Unpermitted Discharge: $2,000 if no violations of water quality
standards, $5,000 if violations of water quality standards.
Failure to install, maintain or operate a pollution control device:
$4,000.
Failure to submit required notification: $1,000.
Failure to prepare, maintain, submit or use required reports or other
documentation $500 .
These amounts could be higher if the violation occurs more than
one time (multi-day) or if there is a history of non-compliance.
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
SWD IW DEP Contacts
 http://www.dep.state.fl.us/southwest/contacts
 The DEP inspector assigned to the County
where the facility is located.
 Phone Number: (813) 632-7600
DEP Tallahassee Contacts
 Allen Hubbard- Industrial Wastewater
Administrator (850) 245-8590
[email protected]
 Abel Agosto - CBP Coordinator (850) 245-8603
[email protected]

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