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DEM Considers Three Wastewater Discharge Permits for Woonasquatucket, Carr Rivers

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Hopkins Hill Sand & Stone LLC has been operating without a Rhode Island Pollutant Discharge Elimination System permit since 2004. (Frank Carini/ecoRI News)

The Rhode Island Department of Environmental Management (DEM) is set to extend wastewater discharge permits to three applicants next month, including the controversial Hopkins Hill Sand & Stone LLC, which has been operating illegally for 17 years.

The Rhode Island Pollutant Discharge Elimination System (RIPDES) program, which regulates discharges into state waters as mandated by the state’s General Laws, plans to extend permits to a trio of companies in early November, pending a possible public hearing.

The public can submit comment regarding each permit to the Office of Water Resources or request a hearing to consider the permits. Written requests for a public hearing can be sent to Samuel Kaplan at 235 Promenade St., Providence, RI 02908 by 4 p.m. Nov. 4. A public hearing will be held Nov. 9 at 5 p.m. if DEM receives requests from more than 25 people.

Hopkins Hill Sand and Stone LLC
Hopkins Hill Sand & Stone, at 190 New London Turnpike in West Greenwich, mines and produces construction sand and gravel, and additionally mines and crushes limestone and granite.

The 139-acre site has been “disturbed as a result of past and present mining and processing operations,” according to DEM. The quarry is surrounded by wetlands to the southwest, west, north, and northeast and is in the vicinity of Fisherville Brook.

Discharge complaints date back to spring 2018, when ecoRI News reported on silt buildup in the brooks and streams of the nearby Big River Management Area. DEM previously had no recorded complaints related to runoff from Hopkins Hill Sand & Stone, but logged an ecoRI News request for comment as such.

However, the state agency was aware the quarry had been operating without a RIPDES permit since fall 2004.

A site inspection in May 2018 confirmed Hopkins Hill Sand & Stone was discharging stormwater associated with on-site industrial activity. DEM sent Hopkins Hill Sand & Stone a noncompliance letter in June 2018, flagging the operation’s violation of the Clean Water Act and state law.

Two subsequent letters were sent in July and October 2018, ordering the quarry to address deficient stormwater management systems and file a RIPDES application “as soon as possible.” No action was taken and a DEM issued a formal notice of violation to Hopkins Hill Sand & Stone — as well as property owner Hopkins Hill Road Realty LLC — in February 2020, issuing a $67,896 fine and requiring parties to immediately cease all processed water and stormwater discharge until a permit was attained.

The resulting RIPDES permit would allow discharge from a series of settling ponds to enter the wetland area and flow into the Carr River, which holds a “Class A” grade according to Rhode Island water quality regulations. Class A waters have “excellent aesthetic value” and are suitable for recreational activities and fish and wildlife habitat.

The permit would be in effect for five years from the date of approval, provided all permit criteria are met.

Annual site evaluations would be conducted, and visual inspections of sediment basins would be required within 24 hours of all rainstorms dropping more than a half-inch. Further inspections would verify pollutant management and drainage map accuracy, ensure outfall and barrier integrity, and track and monitor sediment accumulation, including at vehicle entrances.

Flow rate, total suspended solids (TSS), water hardness, pH level, nitrogen abundance, and perchlorate — a chemical present in rock blasting compounds that can interfere with thyroid function in high dosages — would be monitored, as per the permit.

Data on nitrate and nitrite-nitrogen would be recorded and compared to a Rhode Island sand and gravel mining benchmark of 0.68 milligrams per liter. If the quarterly or yearly average is in exceedance, DEM would re-evaluate facility operations and stormwater prevention plans.

The permit allows no discharge of concrete truck wash water, truck engine wash water, or detergents. Discharges with visible discoloration, sheen, foam, or floating solids are also prohibited.

Material Sand & Stone Corp.
The Material Sand & Stone Corp. produces construction sand and gravel, as well as asphalt paving mixtures, out of North Smithfield. The 105-acre parcel at 618 Greenville Road has been “extensively disturbed as a result of past and present gravel pit operations,” according to DEM.

A rock-crushing operation runs Monday through Saturday, with stone washing occurring intermittently and as weather permits from April to December. The operation, which uses water from the Woonasquatucket River, results in wastewater discharges.

During average precipitation, stormwater is contained on-site by berms, infiltration trenches, and retention basins. But site surveys and drainage calculations show stormwater discharge could occur during flooding events.

The facility’s discharges enter a series of sedimentation basins on-site before feeding out to the wetlands and back into the Woonasquatucket River, which lie to the north and west of the property. The Woonasquatucket River, according to the permit, is recognized as a “Class B” waterbody, which is suitable for fish and wildlife habitat, recreation, and “compatible industrial processes.” However, according to Rhode Island’s 2018-2020 list of impaired waters, the Woonasquatucket River does not support fish and wildlife habitat or primary recreation due to high levels of zinc and the presence of enterococcus.

Material Sand & Stone submitted a RIPDES permit application for these discharges June 8, 2020. DEM showed concern about the facility’s ability to meet limits for total iron and TSS, which serves as a metric for water column particles.

The facility plans to build new treatment ponds to better control the discharges. However, according to DEM, these ponds are only anticipated to lower effluent TSS levels to 41 milligrams per liter — still above the permitted monthly average of 25 milligrams per liter.

As per the permit, total iron and TSS would be monitored quarterly, along with flow rate, pH level, zinc, enterococci, nitrate, nitrite-nitrogen, and perchlorate.

Also, according to the permit, discharges should not discolor the Woonasquatucket River, or add any oil sheen, foam or floating solids. All discharge of detergents, asphalt plant wastewater, concrete truck wash water, and truck engine and undercarriage wash water to surface water is prohibited.

Inspections would occur annually, with additional regular inspection of sediment accumulation, vehicle entrances, seeded topsoil slopes, and the structural integrity of outfall locations, earthen berms, and barriers.

Strawberry Field Estates Inc.
Strawberry Field Estates Inc. sits just southeast of T.F. Green International Airport, at 445 Warwick Industrial Drive in Warwick.

Strawberry Field Estates has operated a groundwater extraction and treatment system on the site — which was formerly a strawberry farm and then used for textile machinery manufacturing — since spring 2002, after notifying DEM of the possibility of off-site migration of contaminated groundwater.

In April, SAGE Environmental, on behalf of Strawberry Field Estates, requested process changes to control the “increased migration of contaminants from the site.”

The facility extracts contaminated groundwater through four submersible pumps on the site and treats it through a process of air stripping and a series of three 1,000-pound granular activated carbon vessels.

Both processes work to remove volatile organic compounds (VOCs) and chlorinated volatile organic compounds (CVOCs), groundwater contaminants common in industrial solvents and often leftover from the manufacturing of paints, pharmaceuticals, and refrigerants.

The treated groundwater is discharged into a catch basin on Strawberry Field Road before making its way into a “Class A” segment of Tuscatucket Brook. The brook, which holds a warm-water fishery designation, flows into Brush Neck Cove less than 2 miles downstream.

The RIPDES permit would allow the facility to increase the maximum daily discharge flow rate to 40 gallons per minute, from 10 gallons per minute as established in a 2015 permit.

DEM analyses determined that treated groundwater discharge has a “reasonable potential” to exceed state water quality criteria for a host of pollutants. Limits for each pollutant were established, with strict limits in place for vinyl chloride, tetrachloroethene, and 1,1-dichloroethylene.

According to the permit notice, DEM determined the increased flow rate would not breach existing antidegradation water quality regulations and that “existing uses would be maintained and protected.”

By increasing the flow rate and allowing for the treatment of larger quantities of contaminated groundwater, the permit aims to establish “an overall decrease of pollutants discharge to surface waters.”

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  1. How do these guys get away with running an illegal activity for so long, then maybe just get slap on the wrist before being allowed to do legally what they’d been doing illegally? I can’t even imagine the real-world metaphors I’d use to compare this kind of behavior by the DEM with.

  2. This activity on the part of DEM is becoming the norm. Step 1: Receive complaint. Step 2: Investigate when they have time. Step 3: Issue letters which they know will be ignored. Step 4: There is no step 4. Simple solution would be to have State Police bar access until compliance and remediation is achieved. As for illegal activity if this were a regular property owner it would have been terminated very quickly years ago.

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