Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
chapter
General VPDES Permit for Discharges of Stormwater from Construction Activities (formerly Part XIV, 4VAC50-60) [9 VAC 25 ‑ 880]
Action 25-880 - 2024 Amendment and Reissuance of the Existing General Permit Regulation - see action summary- extension of comment period
Stage NOIRA
Comment Period Ended on 4/27/2022
spacer

1 comments

All comments for this forum
Back to List of Comments
4/18/22  11:09 am
Commenter: Matt DiBella, Greensite Concrete Washout

End pollution from concrete washout pits!
 

We need stricter requirements and more importantly, consistent implementation of stormwater regulations pertaining to concrete washout material. There is no larger cause of pollution from construction activities today in Virginia than the careless way that washout pits are constructed, maintained, and dismantled. Wash water from concrete has a pH of 12-13, the equivalent of Drain-O, with dozens of toxic heavy metals to boot. Pits are often not lined with a continuous sheet of plastic and drain into the ground. Even if they are constructed correctly, almost nobody allows the prohibited wash water to fully evaporate as required by current discharge regulations. Wash out pits are being cut open to illegally get rid of the wash water by almost every company that uses them. It would take several weeks or even months, in perfect environmental conditions, for the hundreds of gallons of wash water to evaporate. How many sites have you visited that dig a new pit when the old fills up? Probably zero. The pits are dismantled as soon as they fill up and reassembled in the same spot. Where is all the wash water going? Contractors have no choice but to cut them open or scoop up the whole pit’s contents and place all the contaminated water in a dumpster, where it will leak all over the road and be left untreated to contaminate the landfill. The plastic also prevents the concrete from being recycled. There’s no reason we should be generating this much waste when there is an alternative solution. According to a California Department of Transportation report on concrete washout from the Division of Environmental Analysis, Storm Water Program, every mixer generates 16-17 gallons of wash water each time they washout their truck. Pump trucks generate an average of 29 gallons of wash water. Only 10% of wash out material is solids. A 10’x10’ washout pit with a depth of one foot has a volume of 748 gallons or 3.7 cubic yards. When full of material, a pit of this size would contain over 600 gallons of wash water, all of which ends up contaminating the site. Wash out pits have been banned by many states and for good reason, they don’t work. It’s all a dog and pony show, if the water is not removed by a certified pollution abatement company, it will contaminate the environment. Virginia needs to mandate that concrete washout material be stored in a reusable container and the toxic wash water is removed, transported off site, and properly treated by a permitted facility. All of this sounds expensive, but it’s really not. According to the CALTRANS report, the average cost of setting up the washout pit is $300, add to that the overage of fees ($70-$125+ per ton), and cost to dismantle and it’s comparable to paying for a certified pollution control company to provide a reusable container. It would take 44 trucks to fill up a 10’x10’x1’ washout pit. At $1,300+ a load, that’s $57,000+ of concrete to fill up this pit. It costs much less than $1,000 for a concrete washout company to switch out a comparable sized, reusable container. If contractors can pay $57,000 for concrete, they can afford the less than 5% price increase to do so without harming the environment and contaminating Virginia waterways. It’s the wild west on Virginia construction sites when it comes to regulating concrete washout. DEQ can’t handle monitoring so it’s put off on local inspectors, most of whom seem uninformed to the hazards of this material. I’ve personally made dozens of reports of negligent SWPPP violations, submitting photo/video evidence to local governments, and have never seen a fine or stop work order implemented, nor real cleanup of any spill. The inspectors essentially are telling contractors to get rid of the evidence and pretend it never happened. If local inspectors have the time and capacity to write violations for tiny amounts of silt fence coming down or some mud on the street, they have the ability to do a better job of monitoring concrete washout violations. We all have to do better. The construction industry is failing its basic civic duty to not intentionally create pollution. This isn’t a small problem, it happens on hundreds of jobs in every local jurisdiction, every single day. There’s a clear solution to this problem, washout pits need to be outlawed in Virginia. 

CommentID: 121801