Project Number:

2833

Aggregate Industries Permitting and Compliance

SERVICE:

Multi-Site Compliance Programming

DESCRIPTION:

A Tech staff member was responsible for managing environmental permitting and compliance for over 30 complex sites within Aggregate's Northeast region. He simultaneously managed compliance implementation, training and maintenance programs, new permitting and public process approvals, and served as the primary point of contact for compliance regulators and neighboring communities. Compliance program management included air quality permitting, industrial stormwater management (SWPPP), process wastewater discharge, local land use, hazardous chemical management (Tier II), toxics use reduction (TURA), toxics use inventory (TRI), hazardous waste management programs and spill prevention preparedness (SPCC). In addition to providing hands-on operations expertise in the field, Tech staff represented the company at all public hearings, regulatory meetings and hosted numerous site inspections. Based on an impending Consent Decree with EPA and MassDEP, all site compliance requirements were mapped and Tech led field implementation and corrective actions. Unique compliance requirements for each operation type include:

— Aggregates Mining/Sand & Gravel - Tech staff led site management of Local Earth Removal and NPDES permit programs. Tech teamed with site operations to institute rigorous practices to mitigate noise and dust nuisance conditions, treat stormwater and maintain compliance with process water discharge standards.

— Asphalt Batching - These complex air emission and liquid storage facilities required Tech to manage compliance programs keyed on record-keeping, inspection and new equipment installations. Tech provided permit compliance training to site operators that managed process fuel usage, emission control maintenance and tended daily run logs. In addition, Tech led the annual above ground storage tank (AST) testing program and managed new installation permitting with State Fire Marshall and MassDEP.

— Concrete Batching - Managing concrete washout pits, water quality and air emission record-keeping were programs Tech staff managed for at these batching facilities. They led local compliance practices to manage process water pre-treatment, truck washout basins, site housekeeping, and keeping detailed logs of process fuel, run hours and emission control maintenance activity.

— Soils Recycling - Tech staff directed and managed permit compliance with the Beneficial Use Determinations at these soils processing sites. In particular, they developed equipment installation record-keeping and practices for management of seasonal emission sources and processing equipment. These logging procedures captured and maintained critical equipment in-service and operating compliance data to complement existing air quality permitting for the sites.

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Key Points

  • This multi-facility operation required a universal compliance, corrective action and stakeholder management program in response to state and federal enforcement actions and new development initiatives.
  • Tech staff developed a multi-media compliance plan in response to the consent decrees, updated permit guidance for routine operations, developed training of site management practices, installed best management practices and developed site expansion plans.