CONSTRUCTION CONTRACTOR ENVIRONMENTAL TRAINING · 2019-12-14 · •Sediment or suspended solids...

CONSTRUCTION CONTRACTOR ENVIRONMENTAL TRAINING

June 2018

Training Outline

• Land Position

• Stormwater Permit Compliance (AZPDES,

MSGP & CGP)

• Allowable & Unauthorized

Non-stormwater discharges

• Good housekeeping: Work areas, Equipment & Vehicles

• Spill prevention, control, cleanup & reporting

• Spill Prevention, Control, and Countermeasure

(SPCC)

• Clean Water Act - Section 401 Compliance

• Materials handling: Storage, Fuels, Oil &

Chemicals

• Waste and Recycling Requirements

• Cultural & Biological Resources Protection

• Light Pollution Control• Fire Prevention• Air Permit Compliance

2

Land Position

3

Land Position

• Rosemont’s Project is located on Federal, State and Private Land

• Permit conditions due to these varying land ownerships are specific and not negotiable

• In general:

• No cross country travel is allowed

• Work areas will be strictly enforced

• Authorized personnel only may work behind restrictive/protective fencing

• Resource protective measures such as lighting, fire, or archaeological requirements can be enforced by

the Forest Service

• Non-compliance with ANY measure cited in a permit, authorization, or contract term can result in

removal from the project and the contractor will be responsible for any fines associated with non-

compliance

4 4

Stormwater Permit Compliance

5


• Personnel must be trained at least annually with documented protocols on the following:

• Use, goals, and requirements of the SWPPP

• Spill prevention, control, and response procedures

• Good housekeeping and materials management

practices

• Other control measures in the SWPPP

• Stormwater monitoring, sampling, inspection,

reporting, and documentation requirements (for

individuals who will perform these tasks).

EMPLOYEE TRAINING

6


• Stormwater Permit: AZPDES Multi-Sector Mining General Permit (MSGP) and Construction General Permits (CGP)

• The objective of the MSGP and CGP is to ensure implementation of best management practices (BMPs) that will minimize and control pollutants in stormwater discharges from industrial and construction activities

• Permit requirements are spelled out in Rosemont’s Stormwater Pollution Prevention Plan (SWPPP) and include:

• Preparation and maintenance of SWPPP

• List of potential pollutant sources

• Implementation of BMPs and erosion/sediment controls in work areas

• Structural controls (such as berms and straw wattles)

• Non-structural controls (such as good housekeeping procedures)

7


• A copy of the Rosemont’s SWPPP will be provided to Contractors.

• Contractors shall review and comply with all requirements in Rosemont’s SWPPP (Note: SWPPP’s are site dependent).

• Clarifications will be provided to Contractors (by the Rosemont Environmental Department) in writing and SWPPP amended accordingly.

8

Stormwater Permit ComplianceTYPICAL CONSTRUCTION ACTIVITIES• Earthworks• Construction of facilities• Storage of gasoline, diesel fuel, used oil• Bulk transfers of petroleum materials from

tankers, tanks and refueling equipment• Equipment Maintenance• Management of solid and hazardous

wastes, and/or recyclable materials • Painting• Washing equipment and vehicles• Clearing/grubbing vegetated areas

POLLUTANTS OF CONCERN• Sediment or suspended solids

• Fuels oil and lubricants

• Hydraulic fluids

• Used oil

• Solvents, cleaning solutions

• Construction specialty compounds

• Paint containing metals and hazardous compounds

• Debris

During construction activities, sediment will be the primary pollutant of concern!

9


Contractors shall:• Maintain construction work areas and

access roads in a clean manner, free of debris without accumulated waste/materials/debris.

• Manage construction sites to prevent fluids, wastes and debris from impacting stormwater (or the environment).

• Comply with inspections to ensure SWPPP compliance.

GENERAL REQUIREMENTS

10


• Stormwater quality is maintained by Best Management Practices (BMPs) using on-site erosion/sediment control measures.

• BMP DEFINITION: Structural, nonstructural, and managerial techniques recognized to be effective and practical to control pollutants of concern, such as sediment, grease, and animal wastes.

• Some Control Examples:

• Straw wattles

• Earthen construction berms

• Containment berms/pits

• Equipment parking and storage secondary containment

GENERAL CONSTRUCTION SITE CONTROLS

11


• Allowable discharges under the StormwaterPermit, other than non-impacted stormwater, include:

• Uncontaminated groundwater and/or spring water;

• Potable water from testing of potable water

systems/sources;

• Firefighting activities;

• Water used to control dust;

• Routine external non-detergent building wash-down; and

• ADEQ De Minimis Permit well pump test discharges with

erosion/scour protection.

12

ALLOWABLE NON-STORMWATER DISCHARGE

12


• Any discharge not specifically authorized by the Stormwater Permit

• Examples include:• Un-treated sanitary wastewater;• Operations and drilling fluid/mud

seeps/discharges;• Oil and grease leaks and discharges;• Truck/equipment wash water;• Plant and soil debris from clearing

operations;• Cleaning detergent and soap; and• Construction debris.

WHAT IS AN UNAUTHORIZED NON-STORMWATER DISCHARGE?

13


• General structural larger scale BMPs include, but not limited to, the following:• Diversion channels;

• Stormwater/unlined ponds;

• Lined ponds; and

• Sediment control structures.

LARGER SCALE STRUCTURAL BMPS/SEDIMENT CONTROL MEASURES

14


• Erosion / sediment control measures include:• Earthen berms• Flow reducers/check dams

Also –• Hay bales• Wattles or silt fencing• Mulching with straw, seeding, or fabric overlays

SMALLER SCALE STRUCTURAL BMPS/SEDIMENT CONTROL MEASURES

15


• Nonstructural BMPs include:• Good housekeeping practices.• Maintenance and daily checks of

vehicle/equipment.• Proper material handling, storage and waste

management.• Secondary containment of areas where

vehicles and equipment are parked or stored.• Training on awareness, spill response and

reporting procedures.

NONSTRUCTURAL BMPS

16


• Work areas must be maintained in accordance with good housekeeping procedures.

• Industrial products must be entered into the MSDSonline database and pre-approved by Rosemont prior to transporting on-site (see Materials Handling section of presentation).

• All approved products must be stored in appropriate containers (with other compatible materials), labeled, covered if necessary and have secondary containment.

GOOD HOUSEKEEPING - WORK AREAS

17


• All waste materials must be managed in accordance with federal, state and local rules and regulations.

• All materials must be separated by compatibility, regardless of packaging type.

• Drums must be closed and all waste must be properly labeled and stored in secondary containment - which my include bins, plastic drums, pre-fabricated catchments and/or lined impoundments.

Note: Contact the Rosemont Environmental Department immediately to report spills, leaks or any questions or assistance needed with management of any solid or hazardous wastes.

GOOD HOUSEKEEPING – WORK AREAS

18


• Only clean and leak free equipment shall be mobilized to the work sites.

• Equipment will be inspected for safety (good working order, MSHA compliant, etc.) and environmental considerations.

• Environmental considerations include equipment that is:

• Free of leaks

• Free of oil, grease and fuel accumulation

• Free of vegetation

Note: Equipment must be free of vegetation before use/transport to the Project or to different project locations.

GOOD HOUSEKEEPING ‐ VEHICLE & EQUIPMENT

19


• Contractors are required to fill out daily equipment inspection logs to ensure equipment is in good working order per safety training.

• Logs include, but are not limited to, the following:

• Steering;

• Horn, backup alarm;

• Checking tires for punctures, low pressure, or wear;

• Checking all mirrors, glass, head lights, tail lights, wipers, brakes, and emergency brake for

proper function;

• Checking the fire extinguisher for dents, and/or low pressure; and

• Checking the engine oil level, wiper fluid level, and coolant level.

Note: Attenuated backup alarms are required.

20

GENERAL EQUIPMENT CHECKS


21

• A Work Plan is required for large equipment maintenance (regular or breakdown) performed on-site at a designated location.

• The Work Plan shall contain:

• Schedule.

• Management, containment, transport and disposal of spent

materials.

Note: Maintenance products must be approved through Rosemont’s MSDSonline system.

GOOD HOUSEKEEPING - VEHICLES & EQUIPMENT

21


• Equipment washing is only allowed at designated a location with associated structures (i.e. pad, sump, berms.

• No detergents shall be used unless authorized by the Rosemont Safety and Environmental Departments via the MSDSonline system.

GOOD HOUSEKEEPING ‐ VEHICLE & EQUIPMENT

22


Contractor sites must have adequate controls to have ZERO unpermitted discharges from work areas.Site controls that can be used: • Berms and physical barriers

• Earthen Berms• Wattles surrounding excavation spoils• Lined or unlined impoundments with anti-

scouring • Equipment secondary containment• Storage tank secondary containment (holds

110% of largest tank volume plus rainfall from a 25-year, 24-hour storm event)

• Product SDS’s with appropriate storage • Adequate spill kits for the products and product

volumes and proper PPE.

COMPLIANCE SUMMARY

23

Spill Prevention, Control, and Countermeasure (SPCC)

24

• Contractors are required to comply with reporting protocols for safety and environmental incidents, including spills.

• The Contractor shall use Rosemont reporting forms for reporting various incidents including:

• Environmental impact spills

• Injuries/equipment damage

• Near misses

SPCCSPILL PREVENTION, CONTROL, AND COUNTERMEASURE

25

• In the event of a spill or leak petroleum product (i.e., gas, oil, diesel), the Contractor must:

• Immediately notify the Rosemont Environmental

Department.

• If safe, immediately take measures to contain the

spill to the extent possible.

• Document material spilled, amount, location,

media, etc.

• Work with Rosemont Environmental Department

to cleanup the spill.

• File a Rosemont Incident Report.

• Rosemont will determine the proper

management procedures for waste disposal.


26

• Contractors will receive a copy of Rosemont’s Spill Prevention Control and Countermeasures (SPCC) Plan. The SPCC Plan addresses storage, handling, and clean-up of fuel, oil and other petroleum products, etc.

• Contractor shall provide spill kits shall at each work area. Kits must be stocked with the appropriate spill clean up supplies for the work area.

• Know the location and proper use of the spill kits. Pre-shift or daily checks of kits is required.

Note: Contractors may need to provide their own SPCC plan (remote areas).


27

Proper Fuels, Oil and Petroleum Handling and Storage

• Rosemont’s SPCC Plan documents the following procedures for fuels, oils, lubricants and all other petroleum products:

• Dispensing;

• Tanker to storage tank transfers and; and

• Inspections.

Note: Contractors are required to be familiar with all fueling and petroleum handling procedures in the SPCC Plan.


28

Clean Water Act (CWA) 401 Certification

29

Clean Water Act (CWA) 401 Certification

Contractors will be issued a copy of Rosemont’s CWA 401 Certification. It is required to be available on-site at all times.

• Applies to all drainages.

• Regulates surface water quality and sources that

add pollutants to a drainage (i.e., fill activities)

30

CWA 401 Certification

• Contractors MUST comply with the conditions and requirements of Rosemont’s CWA 401 Certification.

• Minimize exposing erodible areas when

clearing, grubbing, or scraping.

• Material placed in the drainage must be stable

after placement and not show signs of

excessive erosion.

• Cease operations in flowing washes.

REQUIREMENTS FOR CONTRACTORS

31


• Sediment and erosion are important concerns for CWA Section 401.

• Contractors must install and maintain erosion control measures before, during, and after all construction and activities that could impact the washes.


32


• There are a variety of erosion /sediment control measures that can be utilized (as discussed earlier in the stormwater section).

• Contractors must inspect and evaluate erosion / sediment control measures after each storm event and repair or replace them as needed.


33


• Construction material and/ or fill material (other than native materials) shall not contribute pollutants to stormwater or drainages.

• Washout of concrete handling equipment must be contained and is strictly prohibited from placement in washes or in an area where runoff may enter a wash.


34


• Allowable construction material that may contact water in washes are:

• Untreated logs and lumber

• Natural stone

• Crushed clean concrete

• Native Fill

• Precast concrete

• Steel, plastic and aluminum (excluding debris)

NOTE: Materials and the activities must be pre-

approved.


35


Vehicle/ Equipment Maintenance:

• Areas for equipment stagging, maintenance and storage must be located entirely outside of any drainage areas.

• Areas for fuel, oil, other petroleum products and waste must be designated and all precautions taken to prevent a release.

• Barriers, covers, shields, secondary containment and other protective devices must be utilized to prevent any construction materials or equipment contaminates from entering drainages.


36


Upon completion of certified activities, areas within any wash or drainage shall be promptly cleared of:

• Construction-related forms and equipment,

• Construction residues, and/or

• Piling, equipment, and plant and other construction debris.


37

Materials Handling

38

Materials Handling

• All materials and chemicals must be stored with proper containment and

cover (if required).

• Do not store containers directly on the ground.

• All containers must be legibly labeled and kept in good condition.

• Storage areas must be clean, well organized and have compatible spill

kits nearby.

• Dumpsters will be used for general solid waste and recyclables.

• Regulated universal/special waste (non-hazardous waste) will have a

designated area with appropriate storage and containers.

• Hazardous waste will have a designated area supervised by the

Rosemont Environmental Department. (Note: refers to conditionally

approved products, i.e., chemicals.)

Note: All conditionally approved hazardous products will have assigned

special handling and tracking requirements for spent or unused portions,

including waste profiling.39

Materials Handling

• Centralized fueling station(s) will be available to Contractors at the main Rosemont Project site.

• Fuel tank(s) will be double-walled with dispenser within a lined, secondary containment.

• Site specific Contractor bulk fuel storage will require approval from the Rosemont’s Environmental Department.

• Unless otherwise approved, refueling tanks located on mobile service/pickup trucks shall be of double-walled construction.

FUEL STATIONS

40

Materials Handling

• Mobile equipment (e.g., drill rigs, service trucks, light plants, rubber tired equipment and portable generators) must have a liner beneath them when parked or stored in their designated areas. Drip pans may be used to collect drips, spills, or leaks on equipment on site for short term periods only if liner space is unavailable.

• Equipment with persistent leaks shall be repaired or removed from the site.

• Removal of oil and/or water collected on a liner must comply with procedures in Rosemont’s SPCC Plan.

Mobile Equipment Containment

41

Materials Handling

• At least two weeks prior to mobilization, the Contractor shall submit requests for product pre-approval of Safety Data Sheets (SDS) for all materials and products to be used on-site (Note: SDS has replaced Material Safety Data Sheets [MSDS]).

• The Contractor shall use Rosemont’s SDS e-binder on the MSDSonline website to upload the SDS/MSDSs for approval.

• Contractor’s designated employees will receive an on-line training session on use of the MSDSonline website.

MATERIAL APPROVAL AND SDS / MSDS APPLICATIONS

42

Materials Handling

• All product requests must be submitted on the MSDSonline website for pre-approval prior to bringing a product on-site. Contractor can request conditional product approval.

• The Rosemont Environmental and Safety Departments will review submittals and approve, reject, or approve with conditions.

• Conditionally approved products will require specific use, handling, storage, and disposal conditions.

• The Contractor will be required to find an acceptable substitute for rejected products.

Material Approval and SDS / MSDS Applications

43

Materials Handling

• Materials used on-site shall be made available for inspection by Rosemont.

• Inspections may include the following locations:

• Vehicles and Equipment

• Tool lockers

• Material storage areas

• Materials found on-site that have not been approved will require same day removal from the site.

MATERIAL APPROVAL AND MATERIAL SAFETY DATA SHEETS

44

Materials Handling

• Contractors will reuse (on-site) as much material as possible at the Rosemont Project to prevent waste of potentially useful materials.

• When unable to reuse, Contractors will be responsible for properly separating reusable/recyclable materials from general waste (trash).

RECYCLABLES

45

Materials Handling

Potential recyclable materials include:

• Scrap metal,

• Wood products,

• Cardboard,

• Landscape materials,

• High-density polyethylene (HDPE) materials, and

• Glass, plastic, aluminum, and paper.

Note: There will no on-site disposal of any waste or

recyclable materials at any of the Rosemont properties.

RECYCLABLES

46

Materials Handling

• Dumpsters, located in a centralized area, will be used for non-regulated General Solid Waste (including recyclables).

• Contractors will separate their recyclable materials and solid waste (non-hazardous) destined for local landfill facilities.

• Contractor must insure all materials placed in an authorized site trash dumpster meet all state, federal and local for guidelines for disposal in local solid waste landfills.

GENERAL WASTE DISPOSAL (TRASH)

47

Materials Handling• Contractor is responsible for ensuring that

their personnel are placing their trash under the dumpster tarp/cover, not on it.

• The Contractor is responsible for ensuring that their personnel secure the tarp/cover of the dumpster when they leave it.

• In the event a Contractor mismanages wastes, such as placement of conditionally approved or unapproved products or universal wastes, into the general waste disposal bins, the contractor shall incur the cost of proper disposal of the bin contents.

48

Materials Handling

• The following general waste materials, (trash), can be accepted by general municipal landfills:

• Clean fill, clean rock (no sulfide-bearing materials) and soil;

• Construction and demolition waste;

• Inert material;

• Landscape rubble;

• Vegetative waste;

• Rubbish;

• Putrescible waste;

• Dry paper and cardboard;

• Empty plastic containers and products; and

• Glass.

49

Materials Handling• Universal and Special Waste materials shall

not be placed in general waste dumpsters. Materials include:

• Sewage, sludge or sanitary wastes;

• Un-punctured aerosol cans;

• Batteries;

• Tires;

• Fluorescent light bulbs;

• Petroleum based or contaminated materials;

• Other liquids or potentially hazardous materials; and

• Unapproved, conditionally approved, or otherwise

inappropriate products and materials.

50

Cultural & Biological Resources Protection

51

• All construction operations require compliance with all Archaeological, Cultural and Biological rules and regulations.

• An approved Environmental Disturbance Permit (Clearance Permit) must be obtained prior to beginning work in previously undisturbed areas. These activities include:

• Vegetation (tree) trimming and/or clearing/grubbing

• Road development work

• Excavations/earthwork

• Prior to gaining access to an area for clearing and grubbing, earthwork, etc., activities such as plant removal, cultural resource and endangered (biological) species surveys must have taken place, included an assessment for the presence of caves and sinkholes.


52


• Ongoing monitoring during earthwork/excavation activities is required for

• Cutural resources

• Biological resources

• Paleontological resources and

• For caves and sinkholes

• In the event that these resources are identified, all activities in that area will be suspended until clearance is obtained from the Forest Service and Rosemont’s Environmental Department gives approval to proceed.

53


• Contractor vehicles must remain on authorized roads, drill pads or cleared and prepared activity sites.

• Off-road travel is strictly prohibited unless specifically authorized by Rosemont’s Environmental Department.

• A Clearance Permit is required for off-road travel.

• Fenced areas can only be accessed by authorized personnel.

• A 15-minute Cultural Resources Training Program (video) has been prepared (play as needed). Includes quiz.

54


• Wildlife may be present

• Avoid encounters with wildlife - do not harass or harm wildlife and convey sightings to Rosemont Security.

Note: If anything more than incidental contact is made, a dangerous situation may arise. Carefully remove yourself from the situation by retreating away from the animal to a vehicle or structure if possible. Contact Rosemont Security and wait for instructions.

55

Light Pollution Control

56

Light Pollution Control - Light PlantsSafe work practice procedures requires the illumination of work sites at night. The Contractor:

• Shall provide portable lighting equipment specifications/configurations for approval prior to mobilizing to site.

• Shall provide a daily log of portable lighting usage including lighting configuration, aimings, products used, and hours of operations per work location.

Lighting will be checked for compliance with requirements prior to mobilization by contractor. Failure to obtain required approvals prior to mobilization may be cause for stop work order.

57

Light Pollution Control - Light PlantsGeneral guidelines for site operation of

portable/temporary light plants are:

• Light plants may only be used during construction

activities occurring before sunrise or after sunset.

• Lighting must be turned off if work activity is

suspended.

• Focus lighting toward the hillside and at an angle

below the horizon or the ridgeline of the immediate

landscape.

• Directing light toward State Route 83, local

residential properties/buildings or the night sky is

strictly prohibited (unless authorized for

special/limited use by Environmental Department).

Other site specific lighting constraints to be

determined.

58

Light Pollution Control - Light PlantsCurrent specifications regarding light plants include:

• Only LED portable work light plants are allowed.

• 2700K or 3000K maximum correlated color temperature (CCT) LED sources.

• A maximum mounting height of about 25 feet.

• Luminaires shall be carefully aimed prior to each work shift to focus light to:

• Capture task area only; and

• Minimize off-site spill light and glare.

• Task lighting shall be extinguished when not needed.

• The following are prohibited from use as portable work lighting at

the Rosemont project:

• LED sources in excess of 3000 CCT

• Any metal halides

• High pressure sodium luminaires

• Balloon lights59

Light Pollution Control - Light Plants• Examples of approved light plant luminaires

include:

• Pontilix PX-12 or PX-80 series, 2700K spot optics only

http://www.pontilux.com/

• Beacon Hubbell Cadet Series or FXL series with yoke,

3000K, 3 x 3 spots maximum

http://www.beaconproducts.com/

https://www.hubbell.com/hubbell/en

• Lithonia DSXF series, 3000K, 3 x 3 spots maximum

http://www.lithonia.com/commercial/dseries+flood+size+

2.html#.U9gipfl7KSp

Note: Additional requirements regarding vehicle/equipment lighting may also apply (contract specific).

60

Fire Prevention

61

Fire Prevention

General guidelines and practices for fire prevention and control, include: • All equipment and vehicles must have a

round-nosed shovel and a fire extinguisher rated 2A:10B:C or larger.

• Where access across natural/vegetated areas is required, travel routes shall be wetted down.

• Vehicles shall be parked on cleared areas (pads/roads/work areas) and not on or over vegetation.

• A “Hot Work Permit” is required prior to performing hot work in all areas. Hot work includes activities such as welding, cutting and grinding.

• Additional requirements pertain to performing hot work in wildland or desert brush areas (i.e., undisturbed/ vegetated/uncultivated/grass areas).

GENERAL GUIDELINES

62

Fire Prevention

Hot work in wildland or desert brush areas shall comply with the following:• The surrounding land is adequately wetted and/or

cleared.• Pre-approved areas will be cleared (as needed)

of vegetation within the plausible range of sparks for the activity.

• An adequate spark shield to prevent sparks from carrying may also be used

• A fire watch shall be in-place and have:• Two-way communication device, • A fire extinguisher rated 2A:10B:C or larger, • A shovel, and/or• Other available means of fire prevention (i.e., water

truck).

• A fire watch shall also watch for fire for 30 minutes after the hot work is complete, with a return check 90 minutes later.

HOT WORK IN WILDLAND AND DESERT BRUSH AREAS

63

Fire Prevention

Rosemont has developed spark protection guidelines outlined below:

• All internal combustion engines shall be equipped with qualified spark arresters that are maintained and unmodified and meet USDA Forest Service 5100-1a or the Society of Automotive Engineers Recommended Practices J335 or J350.

• Mufflers and catalytic converters on all vehicles shall be maintained in good working order.

• Vehicles with catalytic converters shall not be parked or operated in wildland or desert brush areas (i.e., undisturbed/uncultivated/grass areas) unless on a designated roadway.

SPARK PROTECTION

64

Air Permit Compliance

65


• Water trucks shall be used on all areas or activities that could generate wind blown dust.

• Contractors, vendors, service vehicles all must keep under the posted speeds (or as directed by Rosemont).

• Contractors shall log work areas and watering schedules on their daily sheets.

Control fugitive dust emissions is specifically required to meet a “zero visible emissions” standard. Measures that must be taken to meet this standard include:

Dust Control

66


Contractor shall keep a daily log of the following:• Water source used to fill water truck (well, tank, impoundment, etc.)

• Fill time (and duration) and volume of water removed from source (gallons).

• Equipment (water truck) number and operator.

• Locations where water applied (specify roads and/work areas).

In summary, water usage will be tracked by water truck number, well, tank or impoundment number, and individual load volumes and locations applied.

RECORDKEEPING AND REPORTING REQUIREMENTS

67


In addition to water usage requirements, Contractor shall also keep a daily log of the following:• Operating hours for each individual piece of equipment, such as dozers,

graders, water trucks, drill rigs, pickup trucks, etc.• For each piece of the equipment above, serial number, make/model and

size of the engine shall be recorded.• Total mileage travelled on-site of each piece of equipment, including work

site location and/or travel routes:• Heavy Equipment• Drill Rigs• Water trucks• Transport vehicle/pickup truck• Service vehicles and• Any other motorized piece of equipment

• Number and size (in horsepower) of generators used on-site, including operating hours and location used.

RECORDKEEPING AND REPORTING REQUIREMENTS

68

Questions

CONSTRUCTION CONTRACTOR ENVIRONMENTAL TRAINING · 2019-12-14 · •Sediment or suspended solids...

Documents

Transcript of CONSTRUCTION CONTRACTOR ENVIRONMENTAL TRAINING · 2019-12-14 · •Sediment or suspended solids...