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What are portables?
When coverage is required
Permit compliance issues
Application for coverage
Notice to begin operation
The sand and gravel general permit now provides coverage for a portable facility. Portable activities include concrete batch plants, asphalt batch plants, and rock crushers. A portable with permit coverage can operate anywhere in Washington State but must comply with permit conditions just like a permanent site. The following provides general guidance on permit coverage for portable facilities but does not examine all aspects of coverage for these facilities. The permittee is responsible for reading the full text of the permit and complying with all applicable permit requirements.
Coverage as a portable can apply to any equipment that conducts short-term asphalt batch, concrete batch, or rock crusher operations. Short-term mean less than two years at a location. Two extensions of six months are possible.
Portable coverage is not intended to provide an alternative to site coverage for ongoing activities. As an example, a site that has more or less continuous asphalt batch activities, even though these activities are by different portables, is expected to have asphalt batch as a part of site coverage. Or, a concrete batch portable that returns to the same site year after consecutive year is not considered short-term and coverage should be for a permanent concrete batch site.
A portable operation is required to have coverage for the portable whenever it operates at a location that does not have permit coverage for that activity. This includes sites that would not typically require coverage under the sand and gravel general permit. The only exception would be for portables that operate on forestland producing product for forest management activities. These sites require permit coverage only if there is a conveyance of discharge to surface water.
Coverage for a portable is not required when the site already has coverage for that activity. For example, a site may include asphalt batch operation as a part of the site permit even though the owner does not maintain an asphalt batch plant at the site. When the site has included coverage of the activity, the permittee must notify Ecology that the batch operation will occur but separate coverage by the portable is not required.
The sand and gravel general permit requires a monitoring plan, stormwater pollution prevention plan (SWPPP), an erosion and sediment control plan (ESCP), and a spill plan. Portable facilities must also complete these planning documents. The challenge for portables is to create plans that will meet the requirements of each specific site where it will operate. Since the equipment setup and most discharge sources should remain the same, it is recommended that "template" plans be written. When a specific site is identified, the template can be tailored with the specific conditions for that site. For example the SWPPP could include standard language for covered areas of chemicals at all sites that does not require changing. Best management practices (BMPs) to control stormwater, however would require updating each time to accommodate site specific differences. Likewise the monitoring plan and ESCP would be a combination of standard practices for all sites and practices that must be updated for each specific site. The spill plan is not as subject to site specific conditions and may not require modification for each site.
Many of the same BMPs for permanent facilities will be required for portables but designed to be more portable. For example, secondary containment for diesel tanks can be accomplished by using 35-45 mil polypropylene. This can be carried with the plant and installed using an excavation and perimeter berm or using "ecology blocks" or jersey barriers for sidewalls. Other techniques may include provisions for the hasty blockage of culverts or drainage ditches in case of a large spill. Spill cleanup supplies should be available and drip pans should be used for mobile refueling.
There is an additional requirement for portable rock crushers. Coverage for the portable rock crusher is not intended to be a substitute for permit coverage of a mining site. At each site the portable must comply with one of the following four options:
The general permit requires portable operations to restore the site after the operation has been completed. The "Notice of Intent to Begin Operation" requires a description of site conditions before setting up, site alterations to accommodate the operation, and actions that will be taken to restore the site when leaving.
The general rule of site restoration is that the site should look much the same after a portable completes operation and moves on, as it did before operation began. Where access roads and a level setup site already exist, very little may be required beyond removal of equipment. If however, the site requires earth moving to level the site and the construction of access roads, greater attention to restoration of the site will likely be required.
The sand and gravel general permit has an application for coverage and instructions designed specifically for portable facilities. Please contact the "Permit Coordinator" at the Ecology regional office closest to your business office to obtain the application or to obtain additional information. When requesting an application, be sure to request the application for the sand and gravel general permit - portable facilities. You may also apply online.
The permit requires the permittee to notify Ecology of a portable operation at a new site at least 10 days before beginning. A notification form and instructions have been developed for this purpose. This form provides information about the site where the portable will operate. Approval by Ecology is not required before beginning operation unless notified by Ecology that additional information or environmental protection is necessary before operation begins. Portables that will be discharging stormwater to surface waters at a new location must complete public notice requirements.
Washington State law requires Ecology to collect permit fees to cover the costs of wastewater discharge permit administration. A separate fee category is included for portables. Permit fees are set by rule development and are found in Chapter 173-224 WAC. Since fee amounts can change with time, please consult the WAC or call Ecology for the current amount. The fee rule also includes a provision for fee reduction based on economic hardship. Criteria for fee reduction and the amount of the reduction may change over time. Permittees are encouraged to consult the fee rule, Chapter 173-224 WAC or call Ecology to determine if their operation is eligible for a fee reduction based on economic hardship.
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