Crushing a Scrap Facility’s Stormwater Permit Requirements
June 10, 2022
Scrap facilities’ stormwater permits incorporate strict sampling requirements, numeric limits (generally referred to as benchmarks, numeric action levels, or numeric effluent limits), and mandated corrective actions. Furthermore, facilities face emerging challenges with increased regulatory scrutiny within environmental justice communities and communities implementing new stormwater utilities. Good planning can ease the operational, maintenance, and reporting requirements and provide positive results for your facility’s relationship with local communities and regulators.
If your facility is facing scrutiny or requires additional best management practices (BMPs) to meet stormwater permit requirements, follow this simple stepped approach:
Walk the site and identify:
Where flows and drainage pathway issues exist (e.g., ponding areas, flow paths that lead to stockpiles or key operational areas);
Where fluff or sediment may accumulate;
The presence of discoloration of soils or pavements;
Where potential wetlands or other areas that should be avoided; and
Areas where additional stormwater BMPs may be incorporated without interfering with site operations or environmentally sensitive areas.
Improve water flow through problem areas, including re-grading areas to promote gravity flow or incorporate pumped conveyance systems.
Incorporate stormwater treatment systems.
There are many options for treating runoff, including pre-treatment devices, stormwater basins, biofilters, media filters/filtration systems, enhanced vaults, treatment trains, and proprietary systems.
Each site need is different, but a typical approach might consider a BMP that prioritizes 1) removing solids, 2) removing oil, 3) providing reserve area for future additional treatment if needed (i.e., dissolved metals, PFAS, PCBs, etc.),
Where regulations allow, consider constraining treatment capacity to manage the “first-flush” of potential pollutants to optimize the treatment system and reduce the footprint needed, thereby reducing potential impacts on operations.
Good planning and design create effective conveyance and treatment systems that improve stormwater quality and help you meet benchmark requirements. Proactive measures to plan for stormwater treatment systems will help existing scrap metal recycling facilities address corrective action and avoid Additional Implementation Measure (AIM) levels based on their benchmark monitoring results.