Jumping through hoops: strict environmental regulations challenge producer.

There's more to maintaining a strong tradition than just keeping the plant's sign brightly painted at the company gate. It's the ability to do business of high quality using current best business practices.

For concrete producers trying to continue traditions in California, surviving

Just look at San Francisco's Bode Gravel Co. In business for more than 90 years, the firm has grown to become one of the four largest ready-mixed concrete producers in the Bay area. Even with this growth, the producer has a rich family tradition. The current ownership began when Danvers Boardman St. acquired the company in 1987 after more than 50 years of employment. Today, his three sons--Danvers "Dan" Jr., Doug, and Randy Boardman--are managers.

The challenge of continuing the tradition hit the producer hard in the late 1990s. Bode Gravel Co. owners were faced with moving its main ready mix operation because of redevelopment occurring in San Francisco's Mission Bay neighborhood. Plans for a new University of California bio medical campus, supporting lab, and offices forced the concrete plant and other industrial operations to move.

Finding a new home

In the months following the realization that they needed to relocate, the Boardman team realized that finding a suitable site in San Francisco and obtaining the necessary approvals would be a monumental challenge. The real estate research uncovered one small area large enough to support a ready-mixed operation where heavy industrial operations would be allowed. It was on San Francisco's southern waterfront adjacent to the Bayview/Hunter's Point community.

Bode officials negotiated a lease for the property with the Port of San Francisco. But the challenge then only began. The land use was subject to necessary agency approvals and any community concessions necessary to mitigate the industrial operation's impact.

The new site was a 2.5-acre waterfront parcel at the port's Pier 92. Bode wasn't the only company on the hunt for space. The massive redevelopment then taking place in the Mission Bay area had forced the accompanying relocation of many industrial operations. This action had already caught the eye of environmentalists and concerned citizens.

The Bode Gravel Co.'s potential new lease soon became the catalyst for strong community opposition. "We thought the approval process would last three to six months, but instead, it turned into a four-year roller coaster ride through the realities of modern day politics and community-industry co-existence," says Dan Boardman who directed the permitting process.

To succeed, Bode's management team recognized that its traditional way of business would have to change. For example, the production facility in Mission Bay wasn't visually appealing by the new community standards.

And there were other subtle aspects unique to the surrounding community. The producer learned that these concerns of the neighbors in opposition to the plant had been fueled by the sincere belief of many that this relocation was an example of "environmental racism."

"We had never heard this term before, but we soon learned it refers to the intentional siting of polluting industries in communities inhabited mainly by African-American, Hispanics, Native Americans, Asians, migrant farm workers, and the working poor," says Boardman.

Along with this, there was the matter of relationships. "No one wants to accept something they don't want, especially from a stranger," says Boardman. Bode was a stranger to the Bayview/Hunter's Point community and its management knew little about its politics.

And not only was there pressure from the local community, Bay watchers from the metropolitan area were on the alert. "From early in the permitting process, it was apparent that the new plant would have to incorporate every practical environmental control possible and then some," says Boardman.

A beacon of responsibility

The new architectural design of the plant would have to be radically different from the old one. Early community involvement was critical to selling the project and the company.

Bode owners and management attended and spoke at several community meetings and city hearings to assure the neighborhood that Bode would utilize the concrete industry's best available control technology (BACT) in building the plant and in conducting its operations. This commitment to the community would not end with the project's approval.

To address stormwater runoff issues, the entire plant was designed to capture and contain rainfall onsite for re-use as batch water. "We accomplished this by paving the entire site with concrete and installing a 450,000-gallon stormwater retention reservoir, in addition to slurry ponds and concrete curbs around the plant perimeter," explains Boardman.

This design had another purpose. It allows Bode to contain and clean up potentially hazardous spills on site. The concrete paving is graded to allow rainfall that has direct contact with cementitious products to flow into the slurry ponds and reclaimer pits.

The rest of the plant's rainfall flows into a stormwater reservoir from which Bode discharges during heavy rainstorms. Bode maintains an annual stormwater discharge permit with the California Regional Water Quality Control Board, which receives regular discharge sample analysis reports.

Dust control and emissions were obvious community concerns. Bode installed state of the art dust collectors for the silos at ground level to improve the plant's appearance. Bode's permit from the Bay Area Air Quality Management District requires dust collector and throughput readings and be maintained monthly.

The plan also dealt with aggregate. Bode installed material wipers on conveyor belts. According to the operating permit, ground storage of material was to be kept to a minimum. Material that was to be stored on the ground also required containment on three sides and spraying stockpiles with water and a dust inhibitor to maintain a specific moisture content.

Keeping the neighborhood clean was another important operating concern. A vacuum street sweeper works throughout the day sweeping the production site in conjunction with an industry group street sweeping program. A small, but extremely effective wheel wash system was installed where the trucks leave the site.

Bode's air quality permit is among the most restrictive in the state partly because of a voluntary commitment to the community to utilize best available control technology. Bode also received a grant from the air quality district that funded replacing engines with new, less polluting computerized engines in two of the older trucks.

Clean and green

Bode's Hazardous Material Business plan was submitted to the city's Certified Unified Program Agency, the body which implements environmental programs within its jurisdiction. During the process, the city's representative helps the management team identify standard shop practices that could be improved.

Their plan calls for recycling as many maintenance materials as possible: waste oil and filters, antifreeze, batteries, wood, and metal. Mechanics now have hydrophobic mops to clean up oily spills and antifreeze as there are no floor drains in the truck maintenance shop.

The result was effective. Bode was recognized as San Francisco's first and only city-certified "clean and green" concrete producer. But the producer has taken recycling one step further.

Bode Gravel currently is promoting recycled aggregate concrete mixes to contractors and city departments to further reduce waste streams. "This allows us to recycle waste concrete products, save users money over virgin aggregate mixes, and enhance the company's and industry's green image," says Boardman.

Aggregate prices are quite high in the San Francisco market. Virgin aggregates often costs more than $20 per ton delivered. Coupled with equally expensive disposal costs of waste concrete and slurry, the Bode team studied how to deal with mixer drum washout and "come-back" concrete. It was an expensive cost, as Bode routinely must deal with 50 to 100 cubic yards of this returned concrete every day.

To solve this enormous environmental and operational challenge, management installed a turn-key concrete recovery system developed by Knelson Mfg. "We selected it because it was one of the largest capacity systems of its type in the market, and is capable of handling six or more trucks simultaneously without in-flow restrictions," says Boardman.

Sand and gravel are reclaimed and recycled as virgin material. The remaining cementitious material is stored as slurry water in agitated storage tanks and treated with a hydration stabilizer to stop hydration for 48 to 72 hours. This slurry water is then used as mixing water in future batches of concrete.

For Boardman, the recycling effort has been a success. The plant is reusing more than 75 tons of aggregate and puts between 10 and 20 tons of waste cement back into production every day. Furthermore, due to the unique integration of an underground washout material handling trough into the truck right-of-way, substantial truck staging and washout times are saved. This improves trucking efficiency, delivery time, and end-of-day clean-up.

The author is a consultant and the regulatory-compliance manager at Bode Gravel Co. For more, visit www.bodegravel.com.

RELATED ARTICLE: Clock ticks in California.

For the past two years, the Califomia EPA's Central Valley Regional Water Quality Control Board has been working toward upgrading the general waste discharge requirements of the industries that populate this generally agricultural area.

What started as a general action has become industry-specific. For the concrete producers in the control board's region, the proposed change in regulations has meant focusing on the methods they use to temporarily store and recycle process water.

The proposed regulation has received national attention, as many of the nation's largest producers have operations in the district's boundaries. But just as importantly, the discussion has focused even more attention to the enforcement community's increasing concern for protecting groundwater.

The control board's concern as expressed in a 2003 report (updated in April 2005), is the possibility of hexavalent chromium leaching into the area's groundwater from untreated process water stored in below-grade holding sumps. The report notes an investigator detected hexavalent chromium in 78% of the wastewater samples taken at concrete plants. But the greater concern is that concentrations of hexavalent chromium exceeding applicable groundwater limits were found in two-thirds of the samples.

From the control board's viewpoint, this presents a significant risk to the region's groundwater. The staff indicated that the region's general soil type is such that once hexavalent chromite is introduced into the groundwater, it may become mobile and present a danger to nearby vegetable farms. This region of the state produces a large percentage of the nation's vegetables, so this is a significant concern.

Liner protection

To protect groundwater from contaminants, the control board had proposed and was about to enact a new standard that would have required placing impermeable liners under the entire production site, as well as installing a leak detection system in a short time frame.

Along with these capital expenditures, producers would have to develop and execute a continuous groundwater monitoring system at each operation. NRMCA estimates the cost of these updates could exceed $500,000 for each operation.

At mid-July, implementing the control board's plans was on hold. Strong producer opposition caused the delay. Producers opposed for three reasons. The regulation would cause producers to haul more of their waste to landfills, increasing truck traffic, and placing a large burden of the costs on small producers.

The control board said the delay is to "... provide the opportunity for constructive interaction between the Board and the ready-mix and aggregate industries ..."

Over the next few months, an industry task force led by Steve Brussee of RMC/Cemex will work with regulators to develop a more equitable plan. Both sides will work together to provide an analysis of costs, operational impacts, characterization of process water and runoff, sump permeability, and environmental impacts.--RICK YELTON

To learn more about the California Regional Water Quality Control Board's regulatory effort on the concrete production industry, visit its Web site at www.water boards.ca.gov/centralvalley /tentative/index.html.