The U.S. EPA has strict requirements regarding stormwater and process water flowing from your precast concrete plant – but compliance often isn’t difficult.
By Alex Morales
The availability of clean water is unbelievably important to the stability of modern-day society. It is as important to the health of the environment as it is to your own personal well-being. Consequently, there are many regulations that govern how manufacturing facilities handle their water – and sometimes the amount of available information can seem overwhelming.
The U.S. Environmental Protection Agency expects that all manufacturing facilities in the United States behave responsibly and adhere to seemingly stringent requirements regarding water. The truth is that the EPA’s processes are very thorough, but many are easy to follow.
Don’t let your lack of expertise in this area dissuade you from complying fully – it’s not as bad as you may think, and the penalties for neglecting to comply can be detrimental to your bottom line.
Two water-related permits that you should be aware of include stormwater and process water. Obviously these are interrelated, but there are some differences.
If the plant discharges into the stormwater system and you have not already submitted a Notice of Intent (NOI) to do so, you should plan on taking this first step. Don’t be afraid to do this – although many experience some uneasiness about the NOI making the EPA aware of your facility’s operations, it also alerts them of your intent to fully comply with regulations. This is a positive first step, even if you have inadvertently neglected to submit one in the past. Once you become aware that your facility discharges water into the stormwater system (see Fall 2002 MC Magazine article “Let it Rain” for more complete details on the program), you should immediately submit an NOI to your local or regional EPA, whichever has jurisdiction.
You then need to immediately begin preparations to create a Storm Water Pollution Prevention Plan, or SW3P. Your SW3P should outline all the plant-specific responsibilities and operating Best Management Practices that work to reduce or completely eliminate the discharge of stormwater pollutants from the plant. It is important to note that an SW3P is indeed plant-specific, and if you are responsible for more than one plant location, then you will need to create an SW3P for each one.
Creating an SW3P can seem like a daunting task. Although creating the SW3P may take you away from your typical day-to-day tasks for some time, it is very important work than ensures your plant processes do not adversely impact your local water quality. It is as much about protecting the health of individuals as it is about protecting the health of the environment. However noble a task, it does take some time, and some have chosen to outsource the task to local engineering firms. But you are more than qualified to create your own SW3P – after all, who knows your plant better?
Your SW3P requires you to name a Pollution Prevention Team to ensure that individuals at your facility are constantly aware of the potential for stormwater contamination and are prepared to act environmentally responsible while producing precast concrete products each day. It also requires the facility to conduct annual employee training to keep these issues at the forefront of your employee’s minds and to increase awareness beyond the pollution prevention team.
The training should review information already contained in your SW3P, such as a review of the facility’s nonstructural Best Management Practices, or BMPs, so setting a training agenda is relatively straightforward. But you might be more concerned about what “nonstructural BMPs” are at this point. Again, it’s very straightforward.
Any process or structure in place to prevent the discharge of pollutants into the stormwater system is considered a BMP. Nonstructural BMPs might include:
- A regular sweeping schedule
- Equipment preventive maintenance schedule
- Spill prevention and response plan
- An overall good housekeeping program
Chances are that you already have many of these programs in place. The SW3P will serve to document these programs and ensure that you schedule regular training to disseminate the information to your employees.
Sweepers, when used routinely, can keep fine dirt/sand particles off paved roadways and out of the path of major stormwater runoff areas. This can significantly lower the amount of Total Suspended Solids in stormwater.
Obviously, not all the water discharged from your site originates from rainfall. There are process waters as well. Process wastewater is simply any water we use or produce in or around our plants during normal, everyday operations. Typically process wastewaters at a precast concrete manufacturing facility include:
- Coring water
- Condensate from the kiln or curing area
- Vehicle and equipment wash water
- Boiler blowdown
- Cooling water
- Hydrostatic test water
- Air compressor condensate
- Coatings application water (solid and liquid)
This list is far from exhaustive and is dependent on the particular operations at the precast facility. Just by compiling a list of all the sources of process water at your plant, you’ll be off to a good start. These water sources likely contribute to continuous flow from your site, even during dry periods of little to no rain, and a permit is needed for this discharge. The EPA has a detailed application for wastewater permits that must be filled out and submitted. The permit is so detailed that it can easily take nine months to a year to get the permit completely approved.
Do not fall into the temptation of thinking that since many of these sources represent a small volume of water that discharge off of the site may not constitute a violation. In many instances, your state permit conditions may require you to recycle, reuse or pump away this water. It is important to familiarize yourself with the specific permit conditions and discharge rules that govern in your state. Unfortunately, it is impractical to list all of the USEPA-authorized offices in the country, and you are left to do some investigating on your own. You will need to contact your local or regional EPA office, whichever has jurisdiction, for all the appropriate paperwork pertinent to your specific locale.
A listing of state and regional EPA offices is available online via the EPA’s Office of Water Web site at http://www.epa.gov/water/region.html. Do not assume that if you’re not part of the 48 contiguous states that these programs have no impact. It is important to note that all states and many U.S. territories are impacted by these programs, including Guam, Puerto Rico and the Virgin Islands.
Regarding these permits, you may choose to have an in-house employee work to get your plant into compliance, or you may outsource it to a local engineer or consultant. While there are monetary benefits to handling it in-house, you should weigh the expertise of an outside consultant as well. Individuals who go through the permitting process many times may have established rapports with the individuals who will approve the permit and already understand the types of common errors that are typically caught. The process may or may not go faster than if you handled it in-house. Regardless of which avenue you choose, however, the NPCA Guide to Stormwater Pollution Prevention Plans can be helpful. If you choose an outside consultant, he or she may not be familiar with the precast industry, and these materials can also prove helpful.
If you are unsure whether or not your facility needs to be permitted under the EPA’s Office of Water, you should take every step to familiarize yourself with these programs. The EPA website has information on both these programs, and you can always call on the NPCA TechTeam to help answer any questions you may have.