Armstrong Asked - Are we Sure We Have the Right Stormwater Permit?
Issue: After performing an internal environmental compliance audit, Armstrong personnel identified a number of kiln water drains discharging above ground around the plant. Armstrong contacted Pickering and asked for a comprehensive determination on what process water was being generated at the plant, where it goes and how must it be permitted.
Approach: In order to get a full picture of what process water was being generated and where it was being discharged, Pickering performed an in depth water study. With the results, Pickering held a second site visit with a State representative from TDEC where we presented our findings and discussed how best to permit the plant.
Tasks: Activities executed on this assignment included:
- Performing a detailed site visit to identify all sources of process water discharge, their routes above and underground, and their discharge points.
- To investigate the underground drain structure we connected water hoses and identified the discharge locations.
- We also identified all surface flow and re-identified all facility stormwater outfalls.
- Using AutoCAD drawings of the facility, Pickering mapped out all process discharge locations, all underground drains, all outfalls, and all drainage basins, providing a comprehensive picture of the discharge locations for all rain water and process discharge water at the plant.
- Sampling was also performed on Kiln discharge water to identify potential stormwater contaminants.
- Armed with this information, we held an on-site meeting with a representative of TDEC.
- After concurrence with the State, we prepared a revision to the facilities Stormwater Pollution Prevention Plan (SWPPP).
Timeline: Completed January 2007
Result: After visualizing the site and our drawings identifying the discharges, the State concurred that the small volume of process water discharges being released by the Kilns were not required to be covered by an Individual NPDES Permit and continuing coverage by the General Permit was sufficient.