PROJECT OVERVIEW
ESE supported a North Texas aggregates and recycled materials processing facility in Caddo Mills, Hunt County. The site handles outdoor stockpiles, crushing operations, vehicle movement, maintenance, and refueling activities across an active industrial yard. ESE was engaged to prepare a site-specific Stormwater Pollution Prevention Plan for coverage under the TPDES Multi-Sector General Permit, TXR050000. The compliance need focused on Sector J requirements for crushed and broken stone operations.
CHALLENGES
The facility’s primary regulatory driver was TCEQ MSGP compliance for Sector J, SIC 1429, including benchmark monitoring for total suspended solids and pH, annual hazardous metals monitoring, quarterly visual monitoring, and routine inspections. Potential pollutant sources included exposed aggregate and construction material stockpiles, dust-generating activities, diesel refueling, oils and lubricants, DEF, vehicle maintenance, and possible runon from adjacent industrial property. Operational controls also had to address sediment tracking, stormwater flow management, and retention pond discharge procedures.
ESE’S APPROACH
ESE developed a facility-specific SWPPP aligned with TPDES MSGP requirements, Clean Water Act stormwater provisions, and Sector J mineral mining and processing standards. The approach included evaluating drainage patterns, pollutant exposure pathways, control measure effectiveness, receiving water considerations, and monitoring obligations. ESE integrated operational BMPs, structural controls, inspection forms, spill response procedures, and recordkeeping tools into a single defensible compliance document.
KEY ELEMENTS IMPLEMENTED
- Prepared a TPDES MSGP SWPPP for Sector J aggregates operations
- Developed exposed materials inventory and pollutant source assessment
- Mapped drainage areas, stormwater flow, retention pond, and Outfall 001
- Established BMPs for dust suppression, tracking control, fueling, and housekeeping
- Defined benchmark, visual, annual, and routine inspection requirements
- Created spill response, training, rainfall, maintenance, and sampling records
RESULTS
The SWPPP provided the facility with a structured compliance framework for industrial stormwater management under TXR050000. The plan clarified roles for the stormwater pollution prevention team, established inspection and monitoring schedules, and documented controls for sediment, TSS, metals, petroleum products, and operational materials. ESE’s work reduced compliance uncertainty and supported consistent implementation by facility personnel.
PROJECT IMPACT
The project strengthened long-term stormwater compliance for an aggregates-focused operation with exposed stockpiles, mobile equipment, and active material handling. The SWPPP created an audit-ready recordkeeping system and aligned daily operating practices with TCEQ MSGP requirements. The facility gained a practical framework for maintaining permit coverage, evaluating BMP performance, and responding to changing site conditions.
