No Magic BMP in Industrial Storm Water
In 2017, more than 4,000 storm water professionals will attend our webinars, come to our training sessions and talk to us on their sites. They all are looking for that great storm water control measure (SCM) or best management practice (BMP) that will magically reduce their concentrations of zinc or sediment (total suspended solids [TSS]) in their storm water discharges at a reasonable cost. Some facilities get to their breaking point and they are willing to pay almost anything for a solution; we have seen some pay millions of dollars for advanced treatment systems. Unfortunately, there is no magic BMP out there, at least not from what I have seen. For most industrial facilities, there are a few basic BMPs that make up the backbone of their storm water program.
The Basic BMPs
The BMPs that do work are cost-effective and can be implemented with existing staff and resources. However, the fundamentals of your industrial storm water program must be strong and the leadership must be willing to not only spend the time on the BMPs, but also be engaged in the problem (storm water runoff) that is being solved. The best BMPs are typically housekeeping, source control, training and record keeping. Many facilities will admit that they do not spend enough time on housekeeping, but feel that they cannot spare production staff’s time. However, the small housekeeping activities can be integrated into a daily routine and be extremely effective at reducing pollutant concentrations in storm water discharges.
Good Housekeeping & Source Control
Daily trash pickup and ensuring dumpsters, scrap metal bins, and other containers are covered reduces pollutants’ contact with rainfall. As the number one finding or violation when local and regional inspectors visit, keeping dumpsters covered also makes financial sense. Site sweeping can range from a push broom to a regenerative-air vacuum sweeper depending on the site and the potential pollutants. Regardless, daily or weekly sweeping is probably the biggest bang for your buck when it comes to a storm water BMP aimed at reducing pollutant loading in storm water. However, don’t forgot to pay close attention to the indoor work areas, while they are not exposed to rainfall, metal shavings, dust, and grindings can easily be tracked outside on worker shoes. For facilities that have low metal benchmarks or limits they are trying to meet, this extra housekeeping effort can be the difference between costly exceedances and smooth sailing.
Training
Unless your storm water team and colleagues know why they are important and how to best implement them, source control and housekeeping BMPs will not do much for your company. This brings us to our third BMP: training. A well-trained storm water team will know the ins and outs of inspections, sample collection and reporting requirements. Even more important though is getting the production, maintenanc, and janitorial staff up to speed on the company's storm water needs.
We often conduct our in-person training sessions in two parts. We spend the first part with the production, maintenance and janitorial staff, covering the requirements of their company’s industrial storm water or multi-sector general permit, the risks associated with non-compliance (a real shocker for some), the potential pollutants on their site, and what they all can do about it. Typically, this takes half an hour, but can be eye-opening for most of the staff.
The second part of a training session is with the storm water team and lasts about an hour. Here we talk through more permit details and then dive into the site-specific needs, such as how to calibrate a pH meter. They do this calibration with their colleagues during the class, not just listening to me talk. We then will walk their facility, conducting a mock inspection, pointing out potential problem areas, sampling locations and techniques, and talking through the finer points of their BMPs. Training has to be engaging through questions with the staff and hands-on interactions, walking around on the site. Training should not be an annual exercise that results in just a check mark on a sheet of paper; it needs to be engaging and informative for all staff at a company.
Seeing the Difference
Last month, I was walking out of a maintenance facility after a training session we conducted and the four mechanics that just finished up training were huddled around the storm drain in front of their shop. They were discussing the storm drain insert and how it was full of sediment and the steps they needed to take to remove, clean and replace it. As is typical for industrial facilities, these guys have tremendous practical, mechanical skills. By focusing their efforts in the right direction and raising awareness, they saved their company the money typically spent on an outside maintenance contractor by taking ownership and protecting water quality with a few minutes of work. I would consider the training a win-win. The company asked us to come back and do two sessions at each of their five facilities so both shifts could participate.
Record Keeping
The last BMP that we consider one of the core four, is record keeping. Industrial storm water general permits and MSGPs require records to be kept for five years. We see record keeping as more than just a folder or binder of forms and papers, but as a storm water compliance platform to track deficiencies, notify colleagues of necessary corrective actions, and close the loop on those deficiencies. Too often inspections get completed and deficiencies identified, but the problems are not communicated out (e.g., forms go into a binder in the office until the annual audit) or the corrective actions get forgotten about in the rush to complete other tasks. A great record keeping system or storm water compliance platform will be your company’s one central location (likely electronic and online) for the entire team to run the storm water program. By linking the results of your inspections, which identify deficiencies, with the corrective actions and the sampling results, the entire program can operate more efficiently and measure success more easily. By identifying, communicating, and fixing problems on the site, before storm water samples are collected, a storm water compliance system is another cost-effective BMP with enormous impact on a storm water program’s success.
When Basic BMPs Are Not Enough
For some facilities that must meet low benchmarks or limits for metals or nutrients, the basic BMPs are not sufficient. For other facilities, their existing sites’ physical characteristics are not conducive to reducing their pollutant concentrations via the basic BMPs either. For example, a truck company with a maintenance shop located on a large dirt lot is going to struggle to meet benchmarks or limits for TSS. In these situations, advanced SCMs or BMPs such as catch basin inserts or treatment systems are going to be necessary.
However, the basic BMPs are still integral to advanced BMPs’ success. By implementing the basic BMPs to the maximum extent, a company can substantially reduce the costs (capital and ongoing) devoted to the advanced BMPs. For example, a metal recycler can increase street sweeping to daily to reduce TSS and metal particulates. This allows for a more finely tuned treatment system employing less filtration of coarse particles and potentially less of the highly specific filtration media, such as activated carbon, zeolites, and/or biochar used to remove dissolved metals from the storm water. This robust housekeeping BMP means a lower investment upfront and less frequent filtration media exchanges throughout the year.
In addition, advanced BMPs are more complex than their basic cousins and installing a treatment system does not alleviate the training, record keeping, and housekeeping burdens on staff. In fact, it only increases those demands. Now staff will need to understand a new, complex BMP that may require daily or hourly adjustments to maintain effective treatment, especially during storm events. In addition, records are often gathered in real-time or at least daily on the performance of an active treatment system and for those installed belowground, monthly inspections by trained staff need to be well documented.
The next time you have an exceedance in your storm water discharges, look to the basic BMPs and double down on your efforts. Sweep twice as much or conduct quarterly “tailgate” style training sessions. Only after doubling down, then give us a call to talk about a treatment system or catch basin insert.
