Over the last few years, we’ve watched something shift in for Aggregate Processing Operations north of Houston, Texas in the San Jacinto Watershed.
TCEQ inspections used to focus on Stormwater Pollution Prevention Plans (SWPPPs), outfalls, and whether stormwater controls (BMPs) were physically in place.
Now inspectors are also requesting your Professional Engineer/Geoscientist (PE/PG) certified Mine Plans after they show up to your facility. Operators who can’t produce them are receiving notices of violation (NOVs) and potential fines.
What Changed?
In January 2022, TCEQ adopted 30 TAC Chapter 311, Subchapter J, creating enforceable Mine Plan requirements for sand and gravel operations in the San Jacinto River Watershed (Standard Industrial Codes 1442 and 1446).
These rules apply to:
- Construction sand and gravel pits;
- Industrial sand pits; and
- Dry pits and dredge operations.
Why Operators Are Receiving Violations
Most of the NOVs we’re seeing in the San Jacinto River Watershed aren’t because operators ignored BMPs. They’re happening because many operators don’t realize that a certified Mine Plan is required at all. Facilities assume that because they have a SWPPP and MSGP coverage that they are compliant. Under 30 TAC Chapter 311, Subchapter J, they’re not.
TCEQ is now treating Mine Plans and RG-555 BMP documentation as a separate, enforceable compliance program, and many APOs are learning that for the first time during inspections.
If the TCEQ showed up tomorrow, could you immediately produce a PE- or PG-certified Mine Plan that matches what’s actually happening at your facility?
That means a plan that clearly defines:
- Current pit size;
- Mining sequences and active disturbance limits;
- Surface drainage and discharge controls;
- Soil conditions and erosion potential; and
- Integration with other existing plans.
If those elements aren’t clearly documented and certified your operation is exposed.
How EDGE Supports Operators
EDGE develops site-specific, PG-certified Mine Plans designed for compliance with TCEQ inspections.
Our goal isn’t to give you a binder, it’s to give you an implementable, site-specific compliance system aligned with everything you need for coverage under 30 TAC Chapter 311, Subchapter J.
Have inspectors asked for your Mine Plan during recent site inspections?
If you’re unsure whether your operation is required to have a Mine Plan onsite, we’re happy to perform a high-level compliance review and flag issues before TCEQ does.