7 Great Questions from Concrete Environmental Course
Posted on Fri, Dec 16, 2011 @ 02:32 PM
I recently finished teaching the NRMCA Environmental Certification Course, which was held in Orlando Florida. It was a great course, with bright interested students, stimulating discussions, and a great field trip to conduct a comprehensive inspection of a ready mixed concrete plant.
But like always, great questions came up. In fact, some of the best questions I have heard from a class came up during this past course. They're great questions, and all environmental professionals should know the answer to them.
How many of these questions do you know the answer to?
- What is the difference between stormwater and process water / non-stormwater when it comes to NPDES permits? Answer: I try and make this simple by teaching what I call the "dry day test". If you're at your site on a dry day when it isn't raining, and you see water being used as part of the process at the plant, regardless of what it is or where it came from, it's not stormwater - it's non-stormwater or process water. And remember - mixing stormwater and process water creates a commingled process water. You can read more about this here.
- Is having a stormwater permit enough when it comes to discharges from a site? Answer: Only if all you discharge is stormwater, and you can verify that, and conduct regular inspections to ensure that there is nothing else being discharged. Discharge other than just stormwater, and you may be in violation of that stormwater permit you have!
- Do admixtures and liquid colors need to be included in your SPCC plan? Answer: The Federal SPCC regulations only deal with petroleum products, and do not cover admixture chemicals or liquid colors. There may be state or local regulations that require the same sort of management of these materials as petroleum, but they do not (and should not) be included in your SPCC plan.
- Should we be doing environmental audits? Answer: Absolutely, but with great care and caution. Conducting audits can be a tremendously useful tool to guage your level of compliance, and to look for non-compliant areas, but realize that there is a lot of potential liability resulting from this process and the results produced. Proceed carefully, and under the guidance of your corporate attorney or knowledgable consultant.
- What kind of chemicals might trigger TRI reporting at concrete plants? Answer: Any toxic chemical, listed here as a Section 313 chemical, that is present or used at the plant above certain thresholds (usually 25,000 pounds, but much less for some particularly toxic chemicals). For concrete plants, large production facilities may exceed this threshold if they use certain non-chloride accelerator admixtures which contain nitrates, a listed toxic chemical.
- What does sustainability mean to me? Answer: Different things to different people, but the classic definition is something like this - meeting today's resource needs in a manner that doesn't jeopardize the needs of future generations for those resources. Let's not use it all up - let's proceed carefully in order for there to be resources available for future generations. For most of us, this means things like energy, natural resources, etc., managed through sustainable practices.
- Is a SWPPP the same as an SPCC? Answer: No, they are two completely different things. An SWPPP is a Stormwater Pollution Prevention Plan, typically required by a plant's NPDES stormwater discharge permit, while an SPCC plan is a Spill Prevention, Control and Countermeasure plan, required at any plant that contains >1,320 gallons of petroleum products.
How did you do?
There were many other great questions, but these general ones stood out. The students got the answers during the course, and hopefully got the message. How about you? How many of these questions did you get right?
If you don't know the answers to all of these, it might be time to consider some solid environmental training!
Follow us online...