Over the course of the last 20+ years, I've seen a wide variety of concrete facilities, from precast operations with one employee (the guy literally did everything) to huge operations with almost a dozen active plants (with literally hundreds of employees).
Needless to say, I've seen the best and the worst out there. Regardless of your size, product, or organization structure, there's some common environmental issues at every concrete plant I've ever been too.
By and large the concrete industry has figured out how to handle process water. We usually find our clients aren't having an issue with it so much as with stormwater. Specifically, we find that facilities struggle to meet their limits or benchmarks set forth in their stormwater permits, often times resulting in violations, including fines.
We initially recommend to every client out there a relatively simple concept: best management practices. I'm referring to basic housekeeping. Sweeping your facility, getting trash off the ground (give you employees some garbage cans and tell them to stop littering, including cigarette butts), cleaning up oil spills or leaks, etc. Also, make sure you're conducting your monthly inspections to keep an eye on your facility. Make sure the person or people taking your samples have been through stormwater training.
Of course, this all is assuming your facility has a stormwater permit. If you don't, you could be in some serious trouble. Your concrete facility absolutely needs to have a stormwater permit (with the exception of some facilities 100% enclosed within a building). If you don't have a permit, click here to contact us and let's get you covered.
2. SPCC Plans
This is simple. Concrete facilities either need one or don't. You can tell quickly if you count up all the above ground oil tanks on site, 55-gallons and above. Add up all the petroleum you have on site, including empty tanks (the EPA counts empty tanks & drums as full so if they're empty and unused, get them offsite), and if you have over 1,320 gallons, you need an SPCC Plan.
If you have underground tanks in excess of 42,000 gallons, then you need one as well.
SPCC Plans are simple. They're an emergency book to discuss the oil you have on site, how you handle, inspect, and take care of your tanks, and what you would do in case of an accident, or emergency. You have to do monthly inspections, and receive annual SPCC training, and that's pretty much it.
3. TRI Reporting
TRI stands for Toxic Release Inventory. Surely a concrete plant doesn't release toxins, right? Well sort of. I'm going to assume your operation has an air permit, which allows your facility to discharge a small amount of air pollution (in the form of cement dust from your silos). Well it's no secret that cement contains some pretty nasty stuff in it, like lead and mercury, even if only in very, very small amounts. The problem is, if you're a large facility, using a lot of cement, a lot of pollution is being released. That means your facility is releasing toxins in very minute, small amounts.
The USEPA has a program, called TRI Reporting, in which facilities just tell them how much they estimated they released over the course of 1 year. There's no limits, permits, etc. It's just reporting.
The issue is, if you should be reporting, and you're not, the EPA's violations are astounding. I'm talking in the 6 to 7 to 8 figure range, easily. We've personally worked with some companies who initially faced a fine in the tens of millions of dollars for not reporting at several facilities for several years.
The EPA won't let you play dumb with this matter. If you need to be doing TRI Reporting, and aren't, then click here to contact us and let's figure out if your operations are at risk or not.
4. Tier II Reporting
The best thing about the concrete industry is you get to meet a lot of great people. I've met some folks who are really down to earth, giving, and wonderful people to work with. I've come to realize a lot of my contacts at concrete plants really give back whenever they can, including volunteer fire fighting for some, which makes this point even easier to understand.
Your facility stores chemicals, oils, and other materials needed for making concrete. Imagine you facility was on fire, and the fire department showed up. They see a dozen tanks with a mysterious fluid in them. They don't know what in there, and the tanks aren't marked, so the fire fighters aren't talking any chances. Would you?
Tier II Reporting, also called Community Right to Know Reporting, is basically letting your local government, including town, city, county, and sometimes state, know what you store onsite. The goal is to let emergency responders, as well as your neighbors, what kind of materials are at your facility, to avoid any accidents or problems should something awful happen at your facility.
Tier II Reporting isn't pie in the sky reporting for no reason - It's to keep your employees, surrounding neighbors, and emergency personal (who may be your employees) safe from the unknown. Again, like TRI Reporting, if you're not doing Tier II Reporting, and you should, the violations are stiff, and you'll be in some serious trouble.
Obviously each concrete facility is going to have its own environmental issues and problems, but I find these to be universally common at most concrete facilities I visit that are struggling with basic environmental compliance. To learn more about environmental issues at concrete plants, click here to contact us or give us a call at 609-693-8301.