“Managing Shipyard Stormwater Discharges” - InfoHouseinfohouse.p2ric.org/ref/24/23288.pdf ·...

Proceedings of the 2001 Shipyard Environmental Issues Track of the 11th Southern States Annual Environmenal

Conference

“Managing Shipyard Stormwater Discharges”

Co-Sponsored by:

Mississippi Department of Environmental Quality &

U.S. EPA Sustainable Industries Partnership Program Shipbuilding and Repair Industry Sector

Co-Chaired by:

Patrick Killeen Friede Goldman Halter Gulfport, Mississippi

& Dana M. Austin

Dana M. Austin Environmental Consulting, Inc. Jacksonville, Florida

September 24-27, 2001 Gulfport, Mississippi

Introduction The 2001 Shipyard Environmental Issues Track of the Southern States Annual Environmental Conference (“SSAEC”) consists of a series of papers and presentations prepared for, and given at the 11th Southern States Annual Environmental Conference in Boluxi, Mississippi from September 24 – 27, 2001. The Shipyard Track program was sponsored by the Mississippi Department of Environmental Quality (“MDEQ”), and the US EPA Sustainable Industries Partnership Program (“SIPP”) Shipbuilding and Repair Industry Sector. While MDEQ has sponsored the SSAEC for eleven years, this is the first year that a specific track of presentations in the conference were set aside for Shipyard environmental issues. It is our hope that the Shipyard Environmental Issues Track will continue as a portion of the SSAEC for many years to come, and will provide a national conference forum for environmental issues affecting US Shipyards.

2001 Shipyard Environmental Issues Track Proceedings The theme of the 2001 Shipyard Environmental Issues Track theme is “Managing Shipyard Stormwater Discharges.” Many shipyards throughout the United States are in various stages of “struggling” with federal and state stormwater management requirements. While, not unique in this regard, the Shipyard industry sector presents many issues that make implementing an effective stormwater management program difficult. We believe this difficulty results from several commonalities that most shipyards share. These include the following: (1) Shipyards generally are located at, and/or perform industrial operations at the intersection of the three environmental media: air, land and water, (2) Shipyard operations are job-shop in nature, and (3) common Shipyard processes, such as blasting and painting, must move to that area of the yard where the work piece (typically, the ship) is located. As a result, pollutants generated from Shipyard operations tend to be immediately accessible to the environment, and may change frequently in type, magnitude and location of generation/discharge.

While many Shipyards are striving to implement stormwater management programs that result in both consistent compliance and elimination of stormwater pollution, it is probably safe to say that there is no model program that is applicable to all Shipyards. Stormwater “Best Management Practices” that are effective in reducing the pollutant load for a particular facility may be ineffective for others. The installation of engineering controls and stormwater treatment facilities may be cost-effective for some yards, but not others. Each facility must be evaluated, and its stormwater management program developed and implemented, with strict regard to the specific factors that make that yard distinct.

The Shipyard Environmental Issues Track consists of a series of subject area titles, selected by the Track Co-Chairs, intended to provide the conference participant with an in depth overview of the Track’s theme. After the Track subject area titles have been established, experts in the particular subject areas are identified, and requested to prepare a paper and presentation for the Conference. The primary selection factor for the presenters is “real” shipyard experience in developing, implementing and maintaining an ongoing program within their subject area expertise. For example, this year’s presenters included four current and two former shipyard workers; two environmental agency personnel who work with shipyards; and two consultants and one lawyer with extensive shipyard experience. In this manner, we hope to provide practical

and timely information that is immediately useful to Shipyard environmental and production personnel who are actively engaged in implementing a stormwater management program.

If you have questions, comments or require specific information regarding any of the papers or presentations provided in these Proceedings, please contact the specific author(s) of the presentation(s). To receive a copy of the Proceedings in a PDF format, please request a copy from Dana Austin at [email protected].

Patrick Killeen Dana M. Austin Director of Environmental Compliance President Friede Goldman Halter Dana M. Austin Environmental Consulting, Inc. Gulfport, Mississippi Jacksonville, Florida June Carpenter, PhD Teresa Amato, Esq. Technology Transfer Specialist Program Manager Mississippi Technical Advisory Program US EPA Sustainable Industries Partnership Program Mississippi State University Washington, D.C. Mississippi State, Mississippi

Proceedings of the Shipyard Environmental Issues Track Management of Shipyard Stormwater Discharges

1. Shipyard Legal Issues Regarding Stormwater Discharges

a. Legal Requirements for Shipyard Stormwater Discharges i. Joseph Green and John Wittenborn, Collier, Shannon and Rill

b. Citizen Lawsuits i. Shaun Halvax, Southwest Marine, Inc.

2. Shipyard Regulatory Requirements for Stormwater Discharges a. Regulatory Requirements for Shipyard Stormwater Discharges

i. Pat Killeen, Friede Goldman Halter b. Agency Enforcement of Shipyard Stormwater Discharges

i. Ken Kwan, US Environmental Protection Agency, Region III c. Stormwater Permitting of Shipyard Stormwater Discharges

i. Wayne Holt, Atlantic Marine, Inc. and Jim Maher, Florida Department of Environmental Protection

3. Shipyard Stormwater Management a. Shipyard Stormwater Pollutant Sources and Loading

i. Dana Austin, Dana M. Austin Environmental Consulting, Inc. b. Hydroblasting and Waterjetting in the Marine Construction Industry as Related to

Waste Minimization and Pollution Control i. Lydia Frenzel, The Advisory Council

c. Stormwater Control, Collection and Treatment i. Lynwood Haumschilt, LPH Consulting and Barry Kellems, Hart Crowser,

Inc. 4. Technical Issues

a. Laboratory analysis of stormwater i. Jason Mennion, Ingalls Shipbuilding

Managing Shipyard Storm Water Discharges

Legal Requirements for Shipyard Storm Water Discharges presented at the 11th Annual Southern States Environmental Conference

Biloxi, Mississippi September 25, 2001

Joseph J. Green1

Collier Shannon Scott, PLLC Washington, D.C.

Under its plenary authority pursuant to the Federal Water Pollution Control Act ("FWPCA" a/k/a "the Clean Water Act" or "CWA"), as amended, the U.S. Environmental Protection Agency ("EPA") has developed a comprehensive program to regulate the discharge of pollutants into waters of the United States. The authority to regulate is the same regardless of whether the discharged pollutants are in process wastewater or storm water. However, the regulatory programs differ in significant ways. Under its storm water management regulations, EPA proposed a tiered approach to regulating storm water discharges. To date, EPA has implemented that approach through promulgation of several permit programs -- a baseline general permit, an industry multi-sector general permit, and two rounds of municipal permits. These permit programs generally include a Best Management Practices ("BMP")-based approach to control the introduction of pollutants into storm water. EPA also is looking to control storm water discharges through a watershed approach under its Total Maximum Daily Load ("TMDL") program as well as through facility-specific, National Pollutant Discharge Elimination System ("NPDES") permits tailored to the operations and pollutants of individual facilities. This paper describes the scope and evolution of the Storm Water Permitting Program, its legal underpinnings, and where it is likely to go from here. Along the way, the paper defines key terms from the statute and regulations, explains EPA's Clean Water Act authority to enforce the Storm Water Discharge Program requirements and outline the regulatory compliance options available to facilities including shipyards. The paper also describes the relationship between the storm water regulatory program for shipyards and the proposed Metal Products and Machinery categorical effluent limitations guidelines ("ELGs") rule for drydocks and land-based ship construction and repair activities.

History of Stormwater Regulation

The 1972 amendments to the FWPCA -- the Clean Water Act -- prohibits the discharge of any pollutant to waters of the United States unless the discharge is authorized by an NPDES permit. Traditionally, efforts to reduce pollutant discharges have focused on industrial process wastewater and the development of technology-based ELGs to control such discharges. EPA initially exempted most storm water discharges from NPDES permit requirements. However, this policy was overturned by a court as a result of litigation brought by the Natural Resources Defense Council ("NRDC"). See NRDC v. Train, 396 F. Supp. 1393 (D.D.C. 1975), aff'd sub nom., NRDC v. Costle, 568

1Joseph J. Green, a senior associate at Collier Shannon Scott, PLLC, joined the firm's environmental and health and safety practice group in 1996. His practice includes counseling on regulatory compliance and permitting matters under all of the environmental programs, including water, chemicals, air, waste, and right-to-know. His practice and the Collier Shannon Scott, PLLC, environmental practice are national in scope involving representation before Congress, the U.S. Environmental Protection Agency, state regulatory agencies, and federal and state courts. The clients he works with include steel manufacturing companies, shipbuilders, leather tanneries, refineries, and other manufacturing companies and national trade associations representing these industries. He holds a J.D. degree from Harvard Law School (cum laude, 1996), graduated with high distinction from the University of Virginia (B.A., 1993), and is currently pursuing his masters in law from the George Washington University Law School (candidate for LL.M. in International Environmental Law, 2001). For further information, he may be contacted at (202) 342-8849 or via electronic mail at [email protected].

F.2d 1369 (D.C.Cir. 1977). In order to cope with the immense burden on the Agency, the Costle court recognized that EPA may use administrative devices, such as general permits, to help manage the permit workload. Under the Water Quality Act of 1987, Congress amended the Clean Water Act to address, among other things, "storm water discharges associated with industrial activity." These amendments require that such discharges be controlled through permits based on the application of best available technology ("BAT") (or best conventional pollution control technology ("BCT"), depending on the pollutant to be controlled) and, where necessary, water quality-based controls under Sections 301 and 402 of the Clean Water Act. EPA has determined that the general permit, discussed below, taken in its totality, meets the necessary BAT/BCT requirements. On November 16, 1990, EPA promulgated sweeping regulations implementing Section 402(p) of the CWA, requiring most facilities that discharge storm water associated with industrial activity to obtain storm water permits. See 55 Fed. Reg 47,990. Facilities that discharge storm water "associated with industrial activity" though "point sources" are required to obtain permits. EPA embraced the broadest possible definition of "point source" to include any identifiable conveyance from which pollutants may enter the waters of the United States. EPA set forth 11 broad categories of industries that are "associated with industrial activity." Shipyards fall under the second category, which covers a variety of Standard Industrial Classification codes, including SIC code 373 -- ship and boat building and repairing. The 1990 regulations set forth EPA's four-tier approach to storm water regulation. In Tier I, EPA issues general permits to cover initially the majority of storm water discharges associated with industrial activity -- including from shipyards. In Tier II, EPA will target specific facilities within watersheds shown to be adversely affected by storm water discharges associated with industrial activity. Such facilities will be required to obtain individual permits. In Tier III, EPA will target specific industry categories of particular concern for individual and "industry-specific" general permits. Finally, in Tier IV, individual permits will be developed with specific control requirements tailored to facilities which pose significant problems.

Do You Need A Storm Water Permit? Undoubtedly, for shipyards, the answer to the above question is "yes." Responding to the question entails a three-prong legal analysis:

(1) Is the storm water discharge associated with industrial activity? As discussed above, shipyards fall within the categories identified by EPA for which storm water discharges are considered associated with industrial activity.

(2) Is there a discharge of a pollutant through a "point source"? Only discharges of storm water or any other industrial process wastewaters through a "point source" must have an NPDES permit. The definition of point source, however, is extremely broad:

A "point source" discharge is any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural storm runoff.

40 C.F.R. § 122.2. The definition has been interpreted to cover almost any human activity that results in a discernible conveyance of water. Only true "sheet" flow is excluded. The definition of pollutant is similarly broad, encompassing almost anything beyond distilled water, including heat.

(3) Is the discharge to a "water of the United States" or municipal storm sewer?

EPA's jurisdiction under the Clean Water Act is limited to discharges that enter "waters of the United States." Again, this term has been interpreted broadly to cover almost any body of water, tributaries, and wetlands.2 The body of water can be on or off your property. Discharges to such bodies of water are considered "direct" discharges. In addition, EPA regulates discharges to municipal sewer systems -- so-called "indirect" discharges -- to ensure that such discharges do not cause the public treatment works to violate its own NPDES discharge permit, or otherwise interfere with the facility. Accordingly, shipyards must obtain a permit for storm water discharges. While a facility may opt for an individual permit for storm water, most facilities can take advantage of the general permit for shipyards.3

The General Permit for Shipyards

In 1995, EPA issued the multi-sector general permit ("MSGP") to cover storm water discharges from a number of industrial categories. 60 Fed. Reg. 50,803 (Sept. 29, 1995). The rule included specific requirements for "industrial activity from ship and boat building or repairing yards." See 60 Fed. Reg. at 50,992, 51,211. The MSGP was reissued on October 30, 2000. 65 Fed. Reg. 64,746. The MSGP authorizes storm water discharges in States where the NPDES program is not delegated.4 In States with such delegated authority, facilities must comply with corresponding State storm water regulations which typically contain a similar MSGP. A facility becomes covered by the general permit by filing a Notice of Intent ("NOI") to be covered. No actual permit is issued to the facility, but rather the facilities files the NOI for permit coverage with the appropriate regulatory authority and then maintains coverage by complying with the terms of the general permit which are found in the Federal Register or equivalent state regulations. Responsibility for completion of the NOI and for compliance with the terms of the permit falls on the operator of the facility. The general permit contains a number of conditions that are common to all covered industry categories, including:

1. Prohibition of non-storm water discharges. Accordingly, shipyards may not discharge with storm water wastewaters such as bilge and ballast water, sanitary wastes, pressure washwater, and cooling water originating from vessels. These discharges require a separate NPDES permit.

2. Prohibition on discharges of hazardous substances.

3. Preparation and implementation of an Storm Water Pollution Prevention Plan ("SWPPP"), as

discussed below.

4. Storm water monitoring. Requirements include a quarterly visual examination of storm water quality: color, odor, clarity, solids content, foam, oil sheen, and other indicators of pollution. No additional analytical tests are required for shipyards.

The SWPPP requirement is the heart of the general permit. The plan must identify potential sources of pollution which may reasonably be expected to affect the quality of storm water discharges and describe and ensure the implementation of practices which are to be used to reduce the pollutants in storm water discharges. EPA considers the SWPPP to be a dynamic "living document" that is modified and amended over time to reflect various 2Recently, the Supreme Court has limited the reach of the Clean Water Act with respect to "isolated" wetlands that are not considered part of interstate commerce.

3Some states may require shipyards and other facilities to obtain individual storm water permits.

4Forty-three states currently have delegated authority to run the NPDES program. Only Alaska, Arizona, the District of Columbia, Idaho, Massachusetts, New Hampshire, and New Mexico have not been delegated this authority.

changes at the facility. Shipyards must examine the following specific areas in developing an SWPPP: fueling; engine maintenance and repair; pressure washing; painting; sanding; blasting; welding; metal fabrication; loading/unloading areas; waste treatment, storage, and disposal; liquid (i.e., paint, solvents, resins) storage; and material (i.e., blasting media, aluminum, steel, scrap iron) storage. The first element of the SWPPP is the establishment of a Storm Water Pollution Prevention Team that will develop and implement the SWPPP. The responsibilities of each team member must be described. The SWPPP also must identify all activities and materials that may potentially be significant pollutant sources. EPA requires a topographical map, or something similar, and a site map indicating an outline of drainage areas for each storm water outfall. For each drainage area, the plan must predict the direction of flow, and the amount and type of pollutants expected to be present in the discharge. The SWPPP must contain an inventory of materials handled at the site that potentially could be exposed to precipitation. The plan must list significant spills and leaks of toxic or hazardous pollutants that occurred at the facility within the last three years. Permittees must summarize existing sampling data describing pollutants in storm water discharges and identify the possible risks of pollution from the various operations at the facility. SWPPPs also must discuss measures and controls intended to minimize the contact of storm water with pollutants. Such BMPs include:

1. good housekeeping, specifically for the following areas at shipyards -- pressure washing; blasting and painting; material storage; engine maintenance and repair; material handling; drydock activities; and general yard;

2. Preventative maintenance of storm water management devices and facility equipment; 3. Spill prevention and response procedures; 4. Annual (at least) facility inspections; 5. Employee training (annual for responsible employees); 6. Recordkeeping and internal reporting procedures; 7. Sediment and erosion control. Facilities also are required to certify that there are no non-storm water discharges that are mixed with storm water discharges.

Current Issues Regarding Shipyard Storm Water Discharges

Storm water regulation is entering a new phase as part of EPA's increased focus on the TMDL program. The TMDL effort is based on water quality, as opposed to technology-based permit limits. That is, states are required to assign water bodies "designated uses" (e.g., recreation, fishing, industrial) and determine the maximum pollutant loadings necessary to achieve of those uses. States then apportion the allowable loadings among all sources of pollution, including industrial users, agriculture, and storm water. On this basis, permit limits will reflect the apportioned pollutant loads for each facility. One of the more difficult issues in this process is how to assign loadings to non-point sources such as storm water run-off. EPA is in the process of setting policy in this area. Depending on EPA's approach, industrial facilities, including shipyards, could face significantly more stringent permit limits (and allowable pollutant loadings under the TMDL program). For example, if non-point sources are allocated substantial loadings, the pool of loadings available to industrial sources will shrink. Finally, it is important to note that storm water is not covered by the proposed Metal Products & Machinery ("MP&M") ELGs. This rulemaking establishes pollutant limits for process wastewater discharges from shipyard dry docks and on-shore operations. The rulemaking is expected to be finalized by the end of 2002.

Conclusion In sum, shipyards are required to obtain a permit for storm water discharges from their facilities. Unlike process wastewater discharges, however, shipyards may utilize the general permit established by EPA and under similar state regulations. The general permit is largely self-implementing and avoids burdensome application requirements associated with individual facility permits. The Clean Water Act has been a great success in improving the quality of water bodies in the United States over the past three decades. A large percentage of pollutant loadings have been eliminated through the development of technology-based effluent limits, primarily required for industrial facilities. Future water programs will focus more on eliminating remaining sources of pollution and addressing water bodies that remain impaired. These programs, such as TMDLs, are water quality-based and likely to result in more stringent storm water, as well as process wastewater, permits in the near future.

* * * * If you have any questions regarding shipyard storm water requirements or the Clean Water Act in general, please do not hesitate to contact Joseph Green of Collier Shannon Scott, PLLC at (202) 342-8849 or via electronic mail at [email protected].

•1

September 25, 2001Southern States Environmental Conference 1

Managing ShipyardStormwater Discharges

Legal Requirements For Shipyard Storm Water Discharges

Joseph J. Green, Esq.

Collier Shannon Scott, PLLC

Washington, D.C.

(202) 342-8849

[email protected]


History of Storm Water Regulation

! Clean Water Act prohibits the discharge of anypollutant to waters of the U.S. unless authorized by an NPDES permit

! EPA initially exempted most storm water discharges from NPDES permit requirements, but this policy was overturned by a court pursuant to litigation brought by an environmental group

! Water Quality Act of 1987 mandated storm water permits for discharges "associated with industrial activity" -- section 402(p)

•2


Principle Regulations

! November 16, 1990 Final Rule - NPDES permit application regulations for Phase I storm water discharges (55 Fed. Reg 47,990)

! April 2, 1992 Final Rule - Revisions to minimum NPDES monitoring requirements for storm water associated with industrial activity (57 Fed. Reg. 11394)

! September 9, 1992 - Baseline General Permit (57 Fed. Reg. 41297)

! August 7, 1995 - Phase II Rule (60 Fed. Reg. 40229)

! September 29, 1995 - Final Multi-Sector General Permit (MSGP) (60 Fed. Reg. 50803)(Includes shipyard-specific requirements)

! September 30, 1998 - Revised MSGP (63 Fed. Reg. 52430)

! December 8, 1999 - Final Revised Phase II Rule (64 Fed. Reg. 68721)


EPA Permitting Strategy

November 16, 1990 Phase I Storm Water Rule:

! Tier I: Baseline PermittingGeneral permits have been developed to cover initially the majority of storm water discharges associated with industrial activity -- including shipyards.

! Tier II: Watershed PermittingFacilities within watersheds shown to be adversely impacted by storm water discharges associated with industrial activity will be targeted for individual or watershed-specific general permits.

! Tier III: Industry-specific PermittingSpecific industry categories will be targeted for individual or industry-specific general permits.

! Tier IV: Facility-specific PermittingA variety of factors will be used to target specific facilities for individual permits.

•3


What Is Required of You and by When?

It depends -- Are you:

! in a delegated NPDES state or EPA

state?

! subject to the storm water regulations?

! eligible for a general permit?


•4


Are You Subject To A Permit?

Do you have:

(1) a storm water discharge associated with industrial activity;

(2) through a point source;

(3) to a water of the United States?


1. "Storm Water Discharge Associated with Industrial Activity"

! Eleven categories -- 40 C.F.R. § 122.26(b)(14)(i)-(xi)

! Shipyards fall under category (ii), which covers a variety of SIC codes, including 373 -- ship and boat building and repairing

! Regulated activities: discharges from plant yards; access roads; material handling sites; refuse sites; process wastewater disposal; material handling equipment areas; residual TSD areas; shipping/receiving areas; manufacturing buildings; raw material and product storage areas

! Also includes areas of past industrial use (within last 3 years)

•5


2. "Point Source Discharge of a Pollutant"! A "point source" discharge is any discernible, confined, and

discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural storm runoff (40 C.F.R. § 122.2).

! Not "true" sheet flow.! "Storm water" is storm water runoff, snow melt, and surface

runoff and drainage.! Pollutants may be anything beyond distilled water.


3. "Water of U.S. or Municipal Storm Sewer"

! Water of U.S.

- Almost anything, and their tributaries; and wetlands

- Can be on or off your property

! Municipal Storm Drain

- "Indirect" discharge to water of U.S.

- Not combined sewer system

•6


How Do You Comply?! What are the necessary parts of your compliance program? You must:

-- understand the laws and regulations-- get a copy of your permit-- file the appropriate Notice of Intent ("NOI") or individual

application-- develop and implement a SWPPP -- inspect-- document-- other?

~ monitor~ report~ consider special requirements


Storm Water Permitting Options

1. Individual Permit

2. Group Permit

3. General Permit

•7


Individual Permit

! Optional approach for anyone! Customized to a facility's characteristics! Required for certain facilities; existing

permits and effluent guidelines ! Costs ($)

-- Application: <10K to over 50K, plus sampling and analytical (may need SWPPP anyhow)

Group Permit

! For groups of similar companies and operations


General Permit! Must comply with either federal or state GPs

! Major advantage for agencies: address large number of companies relatively quickly, with minimal expenditure of resources

! Certain advantages for industries: easy, low-cost! Essentially self-regulation: requires a notice of intent

("NOI") and a storm water pollution prevention plan ("SWPPP")

! Main disadvantage: how much control is "enough"! Cost

-- NOI: minimal -- SWPPP: $3K - $5K-- Monitoring: depends on industry type and number

of outfalls (shipyards off the hook)

•8


Notice of Intent (NOI)

! The start of the GP process! Identifies your intention (and commitment) to fully comply with

all provisions of the GP! Signature commits you and the company! Violation of permit subjects you and company to stipulated

penalties under the Clean Water Act! EPA - No fee, but states typically charge


Shipyards General PermitLike most GPs, has the following conditions:

1. Prohibits non-storm water discharges--This includes discharge of wastewaters such as bilge and ballast water, sanitary wastes, pressure washwater, and cooling water originating from vessels (requires separate NPDES permit for discharge)

2. Prohibits discharges of hazardous substances, and amounts exceeding reportable quantities in a 24-hour period

3. Requires preparation and implementation of an SWPPP

4. Storm water monitoring

5. Daily maximum effluent limits of 50 mg/l for TOC; 15 mg/l O&G

•9


Storm Water Pollution Prevention Plan (SWPPP)! Two major objectives:

1. Identify potential sources of pollution; and2. Develop and describe practices to reduce pollutants in storm

water discharges

! Specific areas at shipyards that must be identified and evaluated:

--fueling; engine maintenance and repair; pressurewashing; painting; sanding; blasting; welding; metal fabrication; loading/unloading areas; waste treatment, storage, and disposal; liquid (i.e., paint, solvents, resins) storage; and material (i.e., blasting media, aluminum, steel, scrap iron) storage


Storm Water Pollution Prevention Plan (SWPPP) (cont.)

! Major components of SWPPP:

1. Storm Water Pollution Prevention Team: who will develop and implement SWPPP

2. Identify potential pollutant sources (activities and materials)

3. Inventory of exposed materials4. Direction of flows5. List of significant spills and leaks during last 3

years6. Existing discharge sampling data

•10


Storm Water Pollution Prevention Plan (SWPPP) (cont.)

! Describe storm water management measures and controls (BMPs), including:

1. Good housekeeping, specifically for the following areas:-- pressure washing; blasting and painting; material storage; engine maintenance and repair; material handling; drydock activities; general yard

2. Preventive maintenance of storm water management devices and facility equipment3. Spill prevention and response procedures4. Inspections -- monthly, records5. Employee training (annual for responsible employees)6. Recordkeeping and internal reporting procedures7. Non-storm water discharges: identify and certify8. Sediment and erosion control9. Runoff management

! Monitoring and Reporting Requirements-- Quarterly visual examination of storm water quality: color, odor, clarity, solids, foam, oil sheen, and other indicators of pollution

-- No analytical tests required


Current Issues! Total Maximum Daily Loads ("TMDLs")

-- water quality driven initiative-- allocates maximum loadings to sources-- how treat non-point sources like storm

water runoff?

! Metal Products & Machinery ELG-- proposal applies to dry docks and land-

based shipyard facilities-- storm water is not regulated under the

proposal-- covered by MSGP

Managing Shipyard Stormwater Discharges

CLEAN WATER ACT CITIZEN SUITES A CASE STUDY

Sandor (Shaun) Halvax

Manager of Material Business Management Southwest Marine, Inc.

Presented at the 11th Annual Southern States Environmental Conference

Shipyard Environmental Issues Track Gulfport, Mississippi

September 2001

Abstract The Federal Clean Water Act generally allows for the filing of a lawsuit by any party who claims to have been adversely affected by the discharge of another. While the successful filing of a citizen suite requires many facts to be proved, opinions on what is legally required to sustain a successful suite may surprise you. This is a case study of a shipyard that believed it was implementing best management practices and storm water controls, such that it was effectively controlling the operations (and discharges) at it’s facility. This presentation is intended to provide an overview of the Federal Clean Water Act requirements for sustaining/defending an allegation of violation of the Act, and will compare and contrast some specific judicial findings for each of these requirements.

Clean Water Act Implementation 1

The Clean Water Act (CWA)The Clean Water Act (CWA)

A CASE STUDY ON A JUDICIAL VIEW OF THE CLEAN WATER ACT

AND CITIZEN SUITESPresented by:Shaun Halvax, SWM

Southern States Environmental Conference 2001 Shipyard Track


IntroductionIntroduction

This presentation is intended to provide an overview of the outcome of a specific Citizen Suite and identify some of the main themes in the judicial review of allegations related to compliance with the Federal Clean Water Act.



Specific Issues PresentedSpecific Issues Presented

•• The Notice LetterThe Notice Letter

•• StandingStanding

•• Alleged Wrongful ConductAlleged Wrongful Conduct

•• Decision/JudgmentDecision/Judgment

•• Relief GrantedRelief Granted


The Notice LetterThe Notice Letter

•• AdequacyAdequacy

•• Alleged deficiencies inAlleged deficiencies in

–– Development of NPDES/Storm Water PlansDevelopment of NPDES/Storm Water Plans

–– Implementation of plansImplementation of plans

•• HousekeepingHousekeeping



Adequacy of Notice LetterAdequacy of Notice Letter

•• Notice letter must be sufficiently specific Notice letter must be sufficiently specific

as to what is wrongas to what is wrong

–– Notice letter recites permit requirementsNotice letter recites permit requirements


Alleged DeficienciesAlleged Deficiencies

•• The alleged wrongful conduct must be The alleged wrongful conduct must be

ongoingongoing a the time of the filing a the time of the filing of the of the

noticenotice










Article Article llllll StandingStanding

•• RequirementsRequirements

–– Injury in factInjury in fact

–– Fairly traceableFairly traceable

–– RedressableRedressable by favorable decisionby favorable decision



Injury in factInjury in fact

•• Satisfied when plaintiffsSatisfied when plaintiffs

–– “…aver that they use the affected area…”“…aver that they use the affected area…”

–– “…for whom the aesthetic and recreational values… “…for whom the aesthetic and recreational values…

will be lessoned by the challenged activity"will be lessoned by the challenged activity"


Fairly traceable to the Fairly traceable to the challenged activitychallenged activity

•• Scientific certainty not requiredScientific certainty not required

•• Discharge of pollutant that causes or Discharge of pollutant that causes or

contributes to the injuries allegedcontributes to the injuries alleged



RedressableRedressable

•• Favorable decision would redress the Favorable decision would redress the

injury allegedinjury alleged

–– Plaintiff sought injunctive reliefPlaintiff sought injunctive relief










Allegations of Wrongful ConductAllegations of Wrongful Conduct

•• Alleged deficiencies in Written PlansAlleged deficiencies in Written Plans

•• Allegedly inadequate implementation of Allegedly inadequate implementation of

those plans those plans


Development of NPDES/Storm Development of NPDES/Storm Water PlansWater Plans

•• Plans are adequate under the law, irrespective Plans are adequate under the law, irrespective

of what standard is applied.of what standard is applied.

–– BATBAT

–– BCTBCT

–– MEP MEP



Plan ImplementationPlan Implementation--HousekeepingHousekeeping--

•• InspectionsInspections

•• Record keepingRecord keeping

•• Corrective actionCorrective action


InspectionsInspections

•• No permits ever required inspectionsNo permits ever required inspections

•• An early version of a SWPPP included a “Daily” An early version of a SWPPP included a “Daily”

BMP inspection provisionBMP inspection provision

•• Inspections conducted during firstInspections conducted during first--

shift/weekdays onlyshift/weekdays only



Record KeepingRecord Keeping

•• Records were kept for inspections conducted by Records were kept for inspections conducted by

Environmental StaffEnvironmental Staff

•• BackBack--shift and weekshift and week--end inspection/records end inspection/records

were not conducted/recorded in same formatwere not conducted/recorded in same format


Record Keeping StatisticsRecord Keeping Statistics

•• Only 53% of inspections conductedOnly 53% of inspections conducted

–– This statistic is for the number of inspection This statistic is for the number of inspection

reports in the files for the possible days in reports in the files for the possible days in

the prior three years (including weekends the prior three years (including weekends

and holidays) and holidays)



Corrective ActionCorrective Action

•• Timely correction of identified problemsTimely correction of identified problems

–– Same or similar deficiencies noted on several Same or similar deficiencies noted on several

occasionsoccasions

–– Multiple days with same deficiencyMultiple days with same deficiency










Decision/JudgmentDecision/Judgment

•• Findings of FactFindings of Fact–– Plan adequacyPlan adequacy

–– Plan implementationPlan implementation

•• Causal HarmCausal Harm










Relief GrantedRelief Granted

•• Specific DirectivesSpecific Directives

•• PenaltiesPenalties

•• Enforcement ProceduresEnforcement Procedures

•• Attorney’s feesAttorney’s fees


Specific DirectivesSpecific Directives

•• TestingTesting

•• SweepSweep--downs/certificationsdowns/certifications

•• Inspections and Record keepingInspections and Record keeping

•• Water Column TestingWater Column Testing

•• Corrective ActionCorrective Action



Specific DirectivesSpecific Directives

Physical Plant ImprovementsPhysical Plant Improvements

•• ShroudsShrouds

•• PiersPiers

•• BermsBerms


PenaltiesPenalties

•• Violations for 799 daysViolations for 799 days

•• $1,000 per day$1,000 per day

•• Provisional penalty of $799,000Provisional penalty of $799,000



EnforcementEnforcement

•• OversightOversight

•• Reporting RequirementReporting Requirement

•• InspectionsInspections


Attorneys’ feesAttorneys’ fees

•• Plaintiffs awarded attorneys’ fees and Plaintiffs awarded attorneys’ fees and

expert witness feesexpert witness fees



Concluding RemarksConcluding Remarks

•• Review the objectives of your inspection programReview the objectives of your inspection program

•• Record corrective actionRecord corrective action

•• Implement a records retention policyImplement a records retention policy

•• Say what you do, and do what you say in your written Say what you do, and do what you say in your written plansplans

•• GoodGood--faith implementation of environmental programs faith implementation of environmental programs are insufficient as a matter of laware insufficient as a matter of law

•• This case raises the bar with respect to successful This case raises the bar with respect to successful motion for summary Judgment. Discovery/access to motion for summary Judgment. Discovery/access to facility records and site visits are much easier to obtainfacility records and site visits are much easier to obtain


Shipyard Regulatory Requirements for Stormwater Discharges Presented at the 11th Annual Southern States Environmental Conference

Biloxi, Mississippi Tuesday, September 25, 2001 3:00 - 4:30 pm

Pat Killeen, REM

Corporate Director of Environmental Compliance Friede Goldman Halter, Inc

PO Box 3029 Gulfport, MS 39505

(228) 896-2644 [email protected]

Polluted storm water runoff is a leading cause of impairment to the nearly 40 percent of

the surveyed U.S. water bodies which do not currently meet water quality standards set forth by the United States Environmental Protection Agency. Over land or via storm sewer systems, polluted runoff generally is discharged directly into local water bodies. When left uncontrolled, this water pollution can result in a negative effect upon fish, wildlife, and aquatic life habitats; this with not taking into account a loss in aesthetic value in addition to the possibility of creating a threat to public health.

Storm water discharges from shipyard and ship-repair facilities are typically generated by runoff from the facility’s impermeable surfaces such as parking lots, production ways, and other water-resistant areas (e.g., buildings, units under construction) during rainfall and/or snow events. Much of this discharge often contains pollutants in quantities that could adversely affect the water quality of the effluent-receiving stream. With that, most storm water discharges are considered point sources and therefore require coverage by a National Pollutant Discharge Elimination System (NPDES) permit. Why regulations ????

In 1972, Congress enacted the Federal Water Pollution Control Act that set the basic structure for regulating discharges of pollutants to waters of the United States. In 1977, the Federal Water Pollution Control Act of 1972 was amended into what we now know as ‘The Clean Water Act’.

The Clean Water Act is ‘the’ national clean water legislation that comprehensively responds to growing public concern for serious and widespread water pollution. The Clean Water Act is the principal federal law that protects our nation’s waters, including lakes, rivers, aquifers and coastal areas. As authorized originally by Federal Water Pollution Control Act and now the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. In many cases, the

. Page 1


NPDES permit program is administered by an individual state that has obtain USEPA permitting authorization by meeting certain criteria, guidelines and standards set forth by USEPA protocol. Since its introduction in 1972, the NPDES permit program is responsible for significant improvements to our Nation's water quality.

Prior to Federal Water Pollution Control Act /Clean Water Act enactment, water quality within U.S. waterways was in a deteriorating state. Lake Erie was dying; the Potomac River was clogged with blue-green algae blooms that were a nuisance and a threat to public health. Many of the nation's rivers were little more than open sewers and sewage frequently washed up on shore. Fish kills were a common sight and the nation’s wetlands were disappearing at a rapid rate.

In considering the state of the nations waters, the legislation’s primary objective was and

is to restore heightened water quality and maintain that quality within all of the nation's waterways. This objective translates into two fundamental national goals:

• eliminate the discharge of pollutants into the nation's waters, and • achieve water quality levels that renders waterways fishable and swimmable

As stated, the focus is on improving and sustaining the quality of the nation’s waters. The

Clean Water Act provides a comprehensive framework of standards, technical tools and financial assistance to address the many causes of pollution and poor water quality, including municipal and industrial wastewater discharges, polluted runoff from urban and rural areas, and habitat destruction.

For example, the Clean Water Act requires major industries, to meet performance standards to ensure pollution control; charges states and tribes with setting specific water quality criteria appropriate for their waters and developing pollution control programs to meet them. The Act provides funding to states and communities to help them meet their clean water infrastructure needs. The Act also protects valuable wetlands and other aquatic habitats through a permitting process that ensures development, infrastructure growth and other projects/activities are conducted in an environmentally sound manner.

After 25 years, this legislation continues to provide a clear path for clean water and a

solid foundation for an effective national water program. In 1987, amendments were made by congress to the Clean Water Act. In 1990, in response to those amendments, the U.S. Environmental Protection Agency (EPA) developed ‘Phase I’ of the NPDES Storm Water Program. The Phase I program addressed sources of storm water runoff that had the greatest potential to negatively impact water quality. Under Phase I, EPA required NPDES permit coverage for storm water discharges from:

• "Medium" and "large" municipal separate storm sewer systems (MS4s) located in incorporated places or counties with populations of 100,000 or more; and

. Page 2


• Eleven categories of industrial activity, each classified by SIC codes. (The 37 series which is included within the eleven categories, is the module of which shipbuilding/ship repair industry is cataloged as SIC numbers - 3731/3732 respectively)

Guiding principles related to the NPDES permit program

EPA, in coordination with States, the regulated community, and the public develops, implements, and conducts oversight of the NPDES permit program based on statutory requirements contained in the Clean Water Act and regulatory requirements contained in the NPDES regulations. As changes to the NPDES regulations are needed, EPA issues proposed and final rules related to the NPDES permit program. Below is a list of terms, and a brief description of that term, commonly used when operating within much the regulatory arena:

• Clean Water Act –The CWA is a law enacted by Congress and signed by the President that establishes environmental programs, including the NPDES program, to protect the Nation's waters and directs EPA to issue rules on to how implement this law.

• Notices – EPA publishes notices in the Federal Register to provide the regulated

community and interested citizens with important information related to the NPDES permit program. Typical examples of such notices are advance notices of rulemaking, availability of data or reports, public meetings, certain petitions, and information collection requests

• Proposed Rules - When EPA proposes new or revised rules to implement the CWA, they

include a Preamble and the text of the new or revised rule. The Preamble is an introduction to the rule that provides a discussion on what issues and information were considered when developing the proposal. EPA publishes proposed rules in the Federal Register and asks for public comment.

• Regulations - When making changes to the NPDES regulations, EPA first develops a

proposed rule and provides it in the Federal Register for public review and comment. The Federal Register is a federal government-wide collection of important new documents that is published daily. After receiving public comments, EPA develops a final regulation and again publishes it in the Federal Register. Once each year, all final federal rules are compiled into a document called the Code of Federal Regulations.

• Final Rules - After receiving public comment on a proposed rule, EPA revises the rule,

when appropriate, and issues a final rule. Final rules contain a Preamble and the text of the final rule. The Preamble or introduction discusses changes that were made from the proposed rule, what must be done to comply with the final rule, and why EPA chose this approach. EPA publishes final rules in the Federal Register.

• Code of Federal Regulations – The Code of Federal Regulations (CFR) includes the text of all final rules issued in the previous year as well as any existing final rules that did

. Page 3


not change in the previous year. The CFR does not contain proposed or final rule preambles or information concerning a final rule other than the text. Specifically is Code of Regulations (CFR) 40 122- EPA Administered Permit Programs: which includes, The National Pollutant Discharge Elimination System General Permits language

What is Phase I of the EPA’s NPDES Multi-Sector General Permit (MSGP)? The MSGP is the first general permit to provide facility-specific requirements for several types of industrial facilities (shipyards included) within one permit. This permit presents all requirements up front, allowing facility operators to become familiar with, and prepare for, activities such as storm water pollution prevention plan implementation and monitoring prior to applying for stormwater permit coverage. The MSGP-2000 published in the Federal Register on October 30, 2000, replaces the original MSGP that EPA first issued on September 29,1995. What is required of the regulated entities?

40 CFR parts 100 thru 149 contain the USEPA’s Water Program regulatory statues. Specifically with regards to stormwater are part 122-the NPDES program and part 123- state program requirements. The regulated entities must obtain coverage under a NPDES storm water permit and implement storm water pollution prevention plans (SWPPPs) or storm water management programs (both using best management practices (BMP’s)) that effectively reduce or prevent the discharge of pollutants into receiving waters Who’s eligible? The MSGP-2000 covers the same 30 industrial sectors as contained in the MSGP-1995, modified on September 30, 1998. Standard Industrial Classification (SIC) codes and narrative descriptions identify the industrial facilities within each of the 30 sectors. The MSGP-2000 is effective in areas where EPA is the permitting authority in EPA Regions 1, 2, 3, 4, 6, 8, 9, and 10 (with a few exceptions-shipyards are not exempt). Facilities located in these areas and currently covered under the MSGP-1995 must obtain permit coverage under the MSGP-2000. New facilities within regulated industrial sectors must also obtain permit coverage under the MSGP-2000. What are the permit regulation requirements? Like the MSGP-1995, the MSGP-2000 contains general permit requirements (i.e., requirements that pertain to all sectors) and sector-specific requirements (i.e., requirements applicable only to facilities within each of the 30 industrial sectors). Most industrial sectors have visual, analytical, and/or compliance monitoring requirements. What are the permit application/termination procedures? To apply for permit coverage under the MSGP, a facility operator must complete and submit to the appropriate NPDES permitting authority a Notice of Intent (NOI) form. The NOI

. Page 4

http://www.epa.gov/npdes/pubs/msgp-noi.pdf


requests a variety of information, including latitude/longitude of the facility, and information related to the Endangered Species Act and the National Historic Preservation Act . The deadline for submission of an NOI requesting coverage under the MSGP-2000 was January 29, 2001. (The MSGP-2000 preamble and permit contain conflicting information regarding the deadline. EPA intends to publish a technical correction that contains the correct deadline of January 29, 2001.) To discontinue permit coverage, a facility operator must complete and submit to the appropriate NPDES permitting authority a Notice of Termination (NOT) form. The most recent version of the NOT form is available in Addendum E of the Federal Register containing the MSGP-2000.

The following web-base links provide the proposed and the actual permit language of the

MSGP-2000:

• MSGP-2000 (65 FR 64746, October 30, 2000) http://www.epa.gov/npdes/regulations/msgp2000-final.pdf

• MSGP-1995 (60 FR 50804, September 29, 1995)

http://www.epa.gov/npdes/regulations/intro-fs.pdf

• MSGP 2000 - Proposed (65 FR 17009, March 30, 2000) http://www.epa.gov/npdes/regulations/msgp2000.pdf

Phase II of the NPDES program

The Phase II Final Rule, published in the Federal Register on December 8, 1999, requires NPDES permit coverage for storm water discharges from:

• Certain regulated small municipal separate storm sewer systems (MS4s); and

• Construction activity disturbing between 1 and 5 acres of land (i.e., small construction activities).

In addition to expanding the NPDES Storm Water Program, the Phase II Final Rule

revises the "no exposure" exclusion and the temporary exemption for certain industrial facilities under Phase I of the NPDES Storm Water Program.

A large construction activity (is not under the auspices Phase II) of is one that:

• Will disturb five acres or greater; or

• Will disturb less than five acres but is part of a larger common plan of development or sale whose total land disturbing activities total five acres or greater (or is designated by the NPDES permitting authority); and

. Page 5



http://www.epa.gov/npdes/regulations/msgp2000.pdf

http://www.epa.gov/npdes/regulations/msgp2000.pdf


• Will discharge storm water runoff from the construction site to a municipal separate storm sewer system (MS4) or waters of the United States.

A small construction activity (is under the auspices of Phase II) is one that:

• Will disturb one or more and less than five acres of land; or

• Will disturb less than one acre but is part of a larger common plan of development or sale whose total land disturbing activities total one acre or greater (or is designated by the NPDES permitting authority); and

• Will discharge storm water runoff from the construction site to an MS4 or waters of the

United States

In the event a facility does conduct construction activities as described above, a permit must be obtained with coverage under an NPDES construction storm water program. If the USEPA is the NPDES permitting authority for the facility, general permits are the only permit option available. There is a general permit for large construction activities and there will be a general permit for small construction activities in December 2002. In areas where EPA is not the stormwater discharge permitting authority, other types of construction storm water permits may be required; a review of the appropriate local permitting requirements is necessary.

Following are web-links that provide additional information on the general permits for both large and small construction activities:

• Large construction activities- fpub1.epa.gov/npdes/stormwater/cgplarge.cfm?program_id=6

• Small construction activities-

http://cfpub1.epa.gov/npdes/stormwater/cgpsmall.cfm?program_id=6

Again, you must review each specific project as it relates to the regulations and address the permitting requirements fittingly.

In conclusion; with the enactment of both the initial Federal Water Pollution Control Act, the Clean Water Act and various state and local water quality regulations, two-thirds of the nation's waters are now safe for fishing and swimming, the amount of soil lost due to agricultural runoff has been cut by one billion tons annually and phosphorus and nitrogen levels in water sources have been greatly reduced.

The future of water quality within our nation’s waterways lies with continued compliance

with these regulations by all within the municipal, industrial and local community. In attaining that compliance, we can be assured of continued sustainable growth in water quality so that one of our most valuable natural resources is protected for generations to come.

. Page 6

10/25/011



Shipyard Regulatory Requirements for

Stormwater Discharges

10/25/012

Southern States Environmental Conference -Shipyard Track

Why ????• 1972-Congress establishes the Clean Water

Act

The goal:

• To restore the integrity of the nation’s waters by reducing/eliminating the discharge of pollutants into said waters

• Achieve water contamination levels that permit fishable and swimmable conditions

10/25/013


1987- Clean Water Act amended• 1990-In response to the 1987 amendment, the

USEPA develops Phase I of the NPDES program

• Phase I addresses; Eleven categories of industrial activity, category (ii), manufacturing includes shipbuilding and ship-repair

• Additionally, Phase I addressed discharges from Medium & large municipal separate storm sewer systems (MS4s) located in incorporated places or counties with populations of 100,000 or more

10/25/014


Established Regulations• Code of Federal Regulations (CFR) 40,

subsections, 100 - 149, EPA’s Water Programs

• Subsection 122; EPA Administered Permit Programs: The National Pollutant Discharge Elimination System (NPDES)

• Subsection 123; State Program Requirements

10/25/015


National Pollutant Discharge Elimination System

(NPDES)……………..…….?????

• A permitting mechanism that implements regulatory oversight and controls on pollutants being discharged into local waterbodies

10/25/016


NPDES requirements

• Obtain coverage under a stormwater permit

• Permit types:

Individual (facility specific)

Multi-Sector General (MSGP)

10/25/017


NPDES permitting requirements• Individual permit-when?? certain

circumstances where a general permit is either not available or not applicable to a specific facility. A facility operator must obtain coverage under an individual permit that the NPDES permitting authority will develop with requirements specific to the facility (e.g., black/grey water discharges)

10/25/018


NPDES permitting requirements• Multi-Sector General (MSGP)-what ???

contains general permit requirements (i.e., requirements that pertain to all sectors) and sector-specific requirements (i.e., requirements applicable only to facilities within each of the 30 industrial sectors established within the NPDES Phase (I), 11 categories

10/25/019


NPDES permitting requirements• Individual permitting process;

Individual permits are issued at the discretion of the NPDES permitting authority. For more information on individual permit application requirements, please contact the appropriate NPDES permitting authority or read the applicable regulations located at 40 CFR 122.21 and 40 CFR 122.26 (c)(1)(i)

10/25/0110


NPDES permitting requirements• Multi-Sector General (MSGP)

Read page No. 75 of the March 30, 2000 Federal Register describes Sector R (shipbuilding) provisions and perimeters exclusively

• Develop and implement a Stormwater Pollution Prevention Plan (SWPPP) PRIOR to submittal of a Notice of Intent (NOI)

• Incorporate Best Management Practices (BMP’s) into the SWPPP

• Ensure activity will not impact protected species as per the Endangered Species Act

10/25/0111


Web-based tools to assist• March 30, 2000 Federal Register, pg. 75 link:

www.epa.gov/npdes/regulations/msgp2000.pdf

• List identifying the general permit categories:www.epa.gov/npdes/pubs/list.pdf

• Best Management Practices-stormwater evaluation tool:www.bmpdatabase.org/

• EPA Office of Waste Water Management-Stormwater Npdes Program: http://cfpub1.epa.gov/npdes/index.cfm?program

10/25/0112


Web-based tools to assist• Multi-Sector General Permit Notice of Intent:

www.epa.gov/npdes/pubs/msgp-noi.pdf

• Notice of Termination:www.epa.gov/npdes/pubs/notform.pdf

• NPDES Discharge Monitoring Report (DMR) form:www.epa.gov/npdes/pubs/dmr.pdf

• EPA Office of Water Management(home page): www.epa.gov/owm/sw/index.htm

10/25/0113


Web-based tools to assist

• SWPPP Guidance document:www.epa.gov/npdes/pubs/owm0307.pdf

• EPA Office of Waste Water Management-State link page:

http://cfpub1.epa.gov/npdes/linkresult.cfm?program_id=6&link_category=2&view=link

10/25/0114


Web-based tools to assist

• Everything you ever wanted to know about stormwater:

http://cfpub1.epa.gov/npdes/doc/cfm?program_id=6&view=allprog&sort=name

Managing Shipyard Storm Water Discharges

AGENCY ENFORCEMENT OF SHIPYARD STORM WATER DISCHARGES

Kenneth Kwan Storm Water Enforcement Expert, Region 4

U.S. Environmental Protection Agency

Presented at the 11th Annual Southern States Environmental Conference Shipyard Environmental Issues Track

Gulfport, Mississippi

September 2001 Abstract This presentation is intended to provide an overview of EPA’s storm water enforcement program. It will examine the role between the states and EPA in storm water enforcement. The presentation will include information about how efforts are prioritized under EPA’s Storm Water Enforcement Strategy, how EPA determines permit compliance, and the various enforcement responses to violations. Finally, Region 4’s storm water inspection program will be addressed. It will focus on the types of problems and deficiencies cited during inspections at shipyard facilities. Introduction In the past, EPA enforcement has mainly targeted on point sources discharging process wastewater. The focus was on major municipal wastewater treatment plants and industrial facilities which have discharges of over one million gallons per day. The compliance status of these major facilities can be easily determined by the facility’s self-monitoring reports, noncompliance notifications, and on-site inspections. Enforcement efforts by the states and EPA have brought most of these noncompliance facilities back into compliance status. Many of these major facilities were required to upgrade their treatment processes to meet permit limits and/or water quality standards. After more than 20 years of progress, many of our rivers, lakes and streams still fail to meet water quality standards. It became more evident from studies and monitoring data that storm water runoff was a major source of water quality impairment. Currently, five regional states have reported storm water runoff as a major cause of water quality impairment on their biannual report to EPA. In addition, Region 4 has five Total Maximum Daily Load (TMDL) lawsuits requiring EPA to evaluate and address various aspects of storm water runoff and sediment loading from construction activities. Mid-year assessment of the

states by EPA revealed considerable variability in the implementation of state storm water programs. It is important that an effective, integrated and coordinated storm water enforcement strategy be established in full partnership with the eight southeastern states in Region 4. The Role Between the States and EPA in Storm Water Enforcement Region 4 includes the States of Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina and Tennessee. Primary implementation of the storm water program, including enforcement, has been delegated to all eight Region 4 states. There are exceptions, however, where EPA still has primary authority. These involve American Indian Lands and the general National Pollutant Discharge Elimination System (NPDES) permit for construction activity in the State of Florida. Since primary implementation of the federal storm water programs has been delegated, EPA is responsible for overseeing state storm water programs. Region 4's state oversight responsibility includes mid-year and end-of-year review of each state’s enforcement program and oversight of state inspection programs. Additionally, Region 4 is responsible for negotiating annual state work plans containing federal enforcement objectives and priorities, storm water inspection plans, and for storm water technical assistance. EPA’s state oversight role also includes taking the enforcement lead in response to a state referral, when a state fails to take timely and appropriate enforcement action, when there are complex multi-media or national precedent issues requiring huge resources, or in response to citizen notices of lawsuits. Region 4's Storm Water Enforcement Program There are over 30,000 general storm water permits in Region 4. About one-half of this universe of storm water permits is related to construction activities. On a national level, storm water facilities (including Phase I and II) represent 75% of the NPDES universe. Major municipal and industrial facilities represent only 1% of this universe. While individually, these storm water facilities may not have a direct impact on water quality, collectively they pose a water quality concern due to their large numbers (over 300,000 facilities nationally). Region 4's enforcement program follows the basic principals as outlined in EPA’s “2000 Industrial Storm Water Discharge Enforcement Strategy.” The Strategy stresses the need to move away from education outreach and compliance assistance to targeted enforcement to increase compliance. The strategy listed three enforcement priorities: 1) industrial facilities discharging without permit coverage; 2) large construction facilities discharging without permit coverage; and 3) industrial and construction facilities having permit coverage but are not complying with their permit. To implement its Strategy, EPA recommends the following approach: 1) conduct an enforcement sweep across a targeted watershed, stream, segment or geographic area; 2) identify non-filers and industrial sectors with the greatest potential for contaminated runoff; 3) compare lists in local databases (e.g., yellow page, business license, and trade associations) against EPA’s application database to screen out potential non-filer candidates; 4) enlist the use of outside resources that can provide input into the inspection targeting process including citizen complaints and local sediment and erosion control programs;

and 5) send information requests or mass mailings to facilities failing to file for permit coverage. Permit Compliance Determination The states and EPA use several methods to monitor and determine permit compliance. They are as follows: * Self-monitoring reports - EPA’s Multi-Sector General Permit (MSGP) for storm water discharges requires operators of industrial facilities to perform as many as three types of monitoring of their storm water outfalls: visual examination, analytical monitoring, and compliance monitoring. 1) Visual examination provides a simple and inexpensive means to obtain a rough assessment of the storm water quality. These samples should be examined for indicators of possible storm water pollution (i.e., color, clarity, solids, foam, and oil sheen). The visual examinations are required to be performed on a quarterly basis throughout the period of permit coverage and be documented in the facility’s Storm Water Pollution Prevention Plan (SWPPP). Facilities are not required to submit visual examination results to the states or EPA. The results from all visual examination should be used as an indicator of the effectiveness of the facility’s storm water controls. 2) Analytical monitoring (benchmark concentrations). 3) Compliance monitoring (effluent limitations) is required for industry sectors that were determined to have a high potential to discharge a pollutant at concentrations of concern. The Ship and Boat Building or Repair Yards listed under Sector R of the EPA’s MSGP does not require any analytical and/or compliance monitoring. However, the states and EPA may require some Ship and Boat Building or Repair Yards be covered under an individual NPDES storm water permit with effluent limitations to protect water quality standards. The results from compliance monitoring must be reported to the states or EPA to determine compliance with its effluent limitations. * Inspections - The states and EPA normally perform three types of inspections: Compliance Evaluation Inspection (CEI), Compliance Sampling Inspection (CSI), and Performance Audit Inspection (PAI). The CEI is a nonsampling inspection focused on records, SWPPP, and site evaluation. The CSI consists of a CEI inspection and sampling of the storm water discharge. The PAI also consists of a CEI inspection plus a detailed evaluation of the facility’s laboratory procedures. Most of these inspections are unannounced and performed by the states. In some cases, the states and EPA may conduct joint inspections. These joint inspections can be state or EPA lead. * Citizen complaints - EPA views citizen complaints as a viable tool to identify unpermitted and noncompliant storm water facilities. In some cases, EPA has pursued criminal activities (e.g., intentional dumping of hazardous waste into storm drains) through citizen complaints. * Information request letters under Section 308 of the Clean Water Act - Information request letters are used when EPA has a reasonable cause to believe permit violations have occurred. The letter requires a facility to address the nature, the extent, and the scope of any suspected violations. EPA then determines any appropriate enforcement action based on the facility’s response.

* Self-audits - EPA is putting special emphasis on self-audits this year. This policy allows a facility to conduct an environmental audit of its operations and voluntarily disclose any violations discovered to EPA. In exchange, the facility would face a lower penalty than if the violations were discovered by EPA. A facility is not eligible for consideration under the self-audit policy if they are currently subjected to state or EPA enforcement. Enforcement Tools The main enforcement authority for the NPDES Program is found in Section 309 of the Clean Water Act. The Act authorizes the following actions: * Administrative Order (AO) - An AO is a formal enforcement action issued to a facility to remedy multi- violations and may require injuntive relief, such as treatment upgrade or expansion in order to return into compliance. Typically a compliance schedule is provided in an Order. * Class I Administrative Penalty Order (APO) - A Class I APO is a formal administrative penalty action which may seek penalties up to but under $27,500. APOs only assess of penalties and does not contain any type of injunctive relief. * Class II APO - A Class II APO is a formal administrative action where the EPA may seek a penalty up to $137,500. APOs are for the assessment of penalties only and does not require any type of injunctive relief. * Civil Action - This action may be used to pursue an assessed penalty that exceeds $137,500, and when an escalation of enforcement is warranted due to a history of noncompliance, environmental harm, or when extensive injunctive relief and a penalty are both sought. * Criminal Prosecution - This action is used when any individual is found willfully violating the Clean Water Act or providing false statements or sampling results under the Act. These cases are handled by the Regional Criminal Investigations Division. General Categories of Storm Water Violations and Enforcement Response There are six general categories of storm water violations that occur most frequently. They are: 1) discharging storm water and/or process water without a valid permit, 2) permit exceedances, 3) failure to develop a SWPPP or failure to properly develop a SWPPP in accordance with the permit requirements, 4) failure to properly implement the SWPPP, 5) record keeping deficiencies, and 6) failure to submit monitoring reports and failure to monitor correctly. EPA has a wide range of enforcement response to these violations. The levels of response are listed in order of their magnitude which consist of Notice of Violation, AO, Class I APO, Class II.APO, Civil Action, and Criminal Prosecution. EPA decisions in any particular case will be made by applying the law and regulations to the specific facts of the case. In some situations, typical

enforcement response can be conducted in sequence or jump to a higher level of magnitude. Some of the following examples of enforcement response to violations reflect only the actions available to EPA. Other states may have alternative enforcement responses that are equally effective. In addition, EPA may take enforcement action at variance with those actions discuss below. * Discharging storm water and/or process water without a valid permit - This is the most common and most serious type of violation. Discharging storm water and/or process water without a valid permit is a violation of the Clean Water Act and may subject the facility to either, or both an AO or an APO.. * Permit exceedances - This only applies to Ship and Boat Building or Repair Yards that are covered under an individual NPDES storm water permit containing effluent limitations. Failure to meet effluent limitations is a violation of the NPDES permit requirements. Sporadic effluent violations are normally addressed with an informal action such as a notice of violation. Chronic violations, however, may result in formal and/or penalty actions. * Failure to develop a SWPPP or failure to properly develop a SWPPP in accordance with the permit requirements - This type of violations may be addressed with a formal action (e.g., Administrative Order and/or a penalty action) since it would take at least 90 days to develop an effective SWPPP. * Failure to properly implement the SWPPP - In order to properly implement the SWPPP, the permittee is required to install the necessary storm water controls in accordance with the plan, conduct proper employee training, conduct the necessary routine and annual comprehensive site compliance evaluations, conduct the necessary tests to prevent co-mingling of process waste water to storm drains, and conduct good housekeeping measures. Improper implementation of the SWPPP could generally result in an informal action (e.g., notice of violation) requiring an explanation of the violation and efforts to prevent future occurrences. However, continuous or serious deficiencies in the implementation of the SWPPP could escalate to a formal action and/or penalty action. * Record keeping deficiencies - Adequate and updated records are important since they document how a facility is implementing its SWPPP. Records which should be retained in the SWPPP should include, but are not limited to, facility inspection records, non-storm water discharge certification, visual storm water examination data, preventive maintenance forms, employee training records, up-to-date list of significant leaks and spills, good housekeeping logs, and amendments to the SWPPP. Failure to maintain these records for three years is a violation of permit condition. First time violations are generally addressed with an informal action such as a notice of violation. However, continuous record keeping violations may escalate to a formal and/or penalty action. Failure to submit monitoring reports and failure to monitor correctly - This only applies to Ship and Boat Building or Repair Yards that are covered under an individual NPDES storm water permit with effluent limitations. First time violations are generally addressed with an informal action such as a notice of violation. However, continuous record keeping violations may escalate to a formal and/or penalty action.

EPA’s Enforcement of Shipyard in Region 4 EPA has sent out over 400 information request letters to ship and boat building or repair facilities in the State of Florida. Approximately 70% of these facilities submitted a response regarding their permit status. Those not responding were issued Administrative Orders. EPA has issued over 130 Administrative Orders, resulting in a 95% response rate. In 1999, EPA escalated its enforcement to issuance of Administrative Penalty Orders to 20 facilities for their failure to respond to the EPA’s Administrative Orders, and for failing to seek coverage under the storm water general permit. The state and EPA have performed 21 joint inspections in a targeted watershed focusing on state road projects, large construction sites, shipbuilding/repair facilities, and discharges to impaired waters. With EPA’s assistance, the state issued six on-site needed to comply notices, three warning letters, and two notice of violation letters. Also, EPA assisted in training several new state inspectors on conducting storm water inspections. Region 4's Storm Water Inspection Program The goal of EPA’s inspection program is to be pro-active. EPA is moving away from a random shotgun approach to inspection toward a more focused approach, targeting the worst facilities first. This can be accomplished by targeting inspection resources toward priority and/or impaired watersheds not meeting water quality standards, identifying industrial sectors with the greatest potential for contaminated storm water runoff, and conducting enforcement sweeps in a targeted area. Once these targets are identified, the primary role of an EPA inspector is to gather information to assess whether a facility is in compliance with environmental laws and permit conditions. EPA’s storm water inspection involves evaluating the SWPPPs, reviewing records, observing industrial activity areas, examining the Best Management Practices (BMP) controls, and inspecting the outfalls. Storm water facilities having monitoring requirements are subject to inspections evaluating sample collection procedures, laboratory analysis, and data compilation. Typical Problems and Deficiencies Cited During a Storm Water Inspection at Shipyard Facilities * SWPPP - 1) Responsibility of each of the pollution prevention team members are not clearly stated, 2) Failure to identify all potential pollutant sources (e.g., pressure wash area, blasting & painting area, engine maintenance & repair area, welding & metal fabricating area, and dry dock area), 3) Failure to identify all potential pollutants likely to be present in the storm water (e.g., heavy metals, spent abrasives, paint solids, dust, detergents, oil, fuel, spent solvent, and suspended solids), 4) Deficient site map that fails to indicate all surface drainage patterns, storm water outfalls, and structural/nonstructural control measures, 5) Failure to identify all significant materials exposed to rainfall and surface runoff (e.g., fueling area, loading/unloading area, liquid & material storage area, and any outdoor manufacturing/processing activities), and 6) Failure to

revise or amend the SWPPP to reflect deficiencies noted during routine inspections or a major process change. * Record keeping - 1) Missing lists of significant spills and leaks for the past 3 years, 2) No visual inspection records, 3) No routine BMP inspection records of pressure wash area, blasting/sanding/painting area, material storage area, engine & maintenance/repair area, dry dock area and general yard area, 4) No annual site compliance evaluation for evidence of, or potential for pollutants entering the drainage system, 5) Missing training records showing who was trained or topic discussed during the training (e.g., use oil management, disposal of spent abrasive, disposal of vessel wastewater, spill prevention & control, fueling procedure, general good housekeeping, and painting & blasting procedure), and 6) No non-storm water assessment and certification. * Visual observations of industrial activity area - 1) No preventive maintenance program (e.g., cleaning of oil & water separator, cleaning of sediment traps, testing of equipment and systems, and etc.), and 2) Bad housekeeping practices (e.g., blasting/painting during windy conditions, no plastic barriers during blasting or paintings to contain debris, and hosing off instead of sweeping off debris). * Best Management Practices controls - 1) Lack of maintenance, improper design, 2) Failure to implement the BMP according to the SWPPP, and 3) No sediment and erosion control. * Examination of the outfalls - 1) Failure to identify all storm water outfalls, and 2) Co-mingling of pressure wash water, sanitary wastewater, process wastewater, and contaminated ballast & bilge with storm water discharge. * Self-monitoring (only applies to facilities with monitoring requirements) - 1) Failure to sample according to criteria specified in the permit (e.g., failure to sample within thirty minutes to one hour of discharge, and no document to show that samples were collected after 72 hours of dry weather), and 2) Samples were not representative of the discharge. Conclusion The goal of effective enforcement is to accomplish the following: * Create a deterrence for future violations - EPA’s enforcement should promote an attitude change where the violator would learn that it does not pay to violate the storm water permit. * Removes the economic benefit of noncompliance - If a violator has incurred an economic advantage by not installing the necessary storm water controls or treatment upgrades in a timely manner, EPA could recover that cost savings in a penalty action. The objective is to level the playing field with other permittees who have spent the necessary monies to come into compliance in a timely manner. * Return violators to compliance - If it is a design problem, EPA would issue a formal action

(e.g., administrative action) requiring the necessary injunctive relief, usually within a few months. If it is an operation & maintenance problem, EPA would issue a notice of violation requiring the necessary operational change or adjustments within 30 days or a formal action if additional time is required. * Stop activities causing environmental harm - By targeting inspection and enforcement resources both at watersheds failing to meet water quality standards and industrial sectors having the greatest potential for contaminated runoff, would reduce storm water impact to the environment. This document is intended to be a statement of EPA Region 4's policies and principles. It does not establish or affect legal rights or obligations. The document it provides does not substitute for EPA's regulations, nor is it a regulation itself. Thus, it cannot impose legally binding requirements on EPA, the states, or the regulated community, and may not apply to a particular situation based on the circumstances. The states and other EPA Regions may have more stringent or different requirements than those contained here. REFERENCES USEPA. October 1992. Storm Water Management For Industrial Activities: Developing Pollution Prevention Plans And Best Management Practices. EPA 833-R-92-002. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. September 1994. NPDES Compliance Inspection Manual. EPA 300-B-94-014. U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, Washington, DC. USEPA. January 18, 2000. 2000 Industrial Storm Water Discharge Enforcement Strategy. U.S. Environmental Protection Agency, Office of Regulatory Enforcement, Washington, DC. University of South Alabama. Best Management Practices For The Shipbuilding and Repair Industry And For Bridge Maintenance Activities, College of Engineering Report No. 92-2 Gulf Coast States Abrasive Blasting Committee. Recommended Management Practices for Abrasive Blasting, August 2000

1

AGENCY ENFORCEMENT OF SHIPYARD STORM WATER DISCHARGES

U.S. Environmental Protection Agency

Region 4

Presented by: Kenneth Kwan, P.E.404-562-9752

[email protected]

U.S. EPA Region 4

2

ROLE BETWEEN THE STATE AND EPA REGION 4

• States have direct implementation of the Storm Water program– Issue Permit– Review compliance data– Conduct inspections and enforcements– Respond to citizen complaints

• EPA has oversight responsibility– Mid-year and end-of-the-year review of the State’s program– Conduct joint and oversight inspections with the States– Ensure State’s enforcement actions are timely and

appropriate

EPA LEAD ENFORCEMENT

• If the States refer the case to EPA

• If the States fail to take timely and appropriate enforcement action

• When there are complex multi-media or national precedent issues requiring huge resources

• In response to citizen notice of lawsuit

3

EPA –STORM WATER PROGRAM

• EPA 2000 Industrial Storm Water Discharge Enforcement Strategy– Industrial facilities discharging without a valid permit– Large construction sites discharging without a valid permit– Industrial and construction facilities that have permit

coverage, but are not doing anything

EPA –STORM WATER PROGRAM

• Implementation of the Strategy– Use of water quality data to identify hot spots– Use of enforcement sweeps across the targeted

areas– Use of local government resources– Use of business licenses database or yellow

page listings to locate unpermitted facilities– Use of mass mailing

4

PERMIT COMPLIANCE DETERMINATION

• Self-Monitoring Reports

• Citizen complaints

• Inspections

• Information request letters

• Self-Audits

ENFORCEMENT TOOLS

• Informal Actions

• Formal Actions:– Administrative Order – Class I Administrative Penalty Order– Class II Administrative Penalty Order– Civil Action– Criminal Prosecution

5

GENERAL CATEGORIES OF STORM WATER VIOLATIONS• Discharging storm water and/or process water

without a valid permit

• Permit Exceedance

• Failure to develop a Storm Water Pollution Prevention Plan (SWPPP)

• Failure to implement the SWPPP

• Record keeping deficiencies

• Failure to submit monitoring data

• Failure to monitor correctly

REGION 4 –ENFORCEMENT OF SHIPYARD

• Identify non-filers in the State of Florida– 400 Information Request Letters– 130 Administrative Orders– 20 Administrative Penalty Orders

• Joint inspections with State at target watershed

6

REGION 4 –STORM WATER INSPECTION PROGRAM

• Watershed approach

• Sector approach

• Enforcement sweeps

Pro-active

TYPICAL PROBLEMS AND DEFICIENCIES CITED DURING A STORM WATER INSPECTION

• No Storm Water Permit

• Storm Water Pollution Prevention Plan (SWPPP)

• Record Keeping

• Best Management Practices Controls

• Self-Monitoring

7

Typical Problems:SWPPP

• Failure to identify all significant pollutant sources

• Failure to identify all potential pollutants from each significant source

• Deficient site map with no drainage patterns, storm water outfalls, and structural/non-structural control measures

Typical Problems:Record Keeping

• No non-storm water certification

• Missing lists of significant spills and leaks for the past 3 years

• No visual inspection records

• No routine inspection records and/or no annual comprehensive site compliance evaluation

• Deficient training records

8

Typical Problems:Best Management Practices

• Bad housekeeping practices

• No preventive maintenance program

• Failure to implement the BMP according to the SWPPP

• Co-mingling of process wastewater with storm water

Typical Problems:Self-Monitoring

• Failure to sample in accordance with permit requirement

• Samples were not representative of the discharge

9

WHAT DOES EFFECTIVE ENFORCEMENT DO?

• Create a deterrence for future violations

• Removes the economic benefit of noncompliance

• Return violators to compliance

• Stops activities causing environmental harm

Storm Water Resources

EPA Headquarterwww.epa.gov/npdes/stormwater/

EPA Region 4www.epa.gov/region4/water/wpeb/stormwater

ASCEwww.bmpdatabase.org


STORMWATER PERMITTING OF SHIPYARD STORMWATER DISCHARGES “PARTNERING FOR THE ENVIRONMENT”

Wayne S. Holt

Environmental & Safety Director Atlantic Marine, Inc.

James R. Maher Supervisor of Industrial Wastewater for the Northeast District

Florida Department of Environmental Protection

Presented at the 11th Annual Southern States Environmental Conference Shipyard Environmental Issues Track

Gulfport, Mississippi September 2001

Abstract Because of the inherent types of operations, processes and some of the materials utilized in the shipbuilding and ship repair business, these facility are subject to regulatory oversight, specifically in this case, environmental regulation. Subsequently, many of the activities and/or resultant consequences are required to comply with environmental regulations. The regulations are conveyed to the facility in the form of environmental permits. One such consequence that requires permitting, is the discharge of stormwater that may have become contaminated when in contact with the facility. There are many unique facets associated with shipyard operations compared to other industrial facilities. Conventional stormwater management activities that are effective at other types of facilities may not necessarily be effectively implemented at a shipyard. There are numerous factors that contribute to this circumstance. Consequently, the regulatory agency that has permitting authority has a very difficult job in developing a stormwater discharge permit that meets all of the regulatory requirements and can be effectively implemented in a shipyard.

The regulations themselves are very complex and provide for little, if any flexibility to the permit writer to address facility specific issues. And although he may have a great deal of experience in industrial facility permitting, he may not have a good understanding of the inherent constraints to effective stormwater management at a shipyard specifically. On the other hand, the shipyard has intimate knowledge of its operations, but may not understand all of the nuances of the permitting process. This informational gap between the facility and the agency often results in the issuance of a permit that is ineffective or unachievable. It can also result in creating a counter-productive adversarial relationship. The permitting issues associated in these circumstances are not easily resolved, especially within the framework of the “conventional” permitting process.

The solution to this fundamental flaw is: “Partnering”. That is partnering in a collaborative effort, sharing information and ideas toward a mutually beneficial end. Building a team of facility and regulatory agency personnel to examine every aspect of stormwater management at


the facility and to develop a stormwater discharge permit predicated on the findings of the team’s analysis. A stormwater permit that can be effectively implemented in the shipyard and that goes beyond standard compliance to provide maximum protection of the environment, where feasible. Atlantic Marine, Inc. (AMI) and the Florida Department of Environmental Protection (FDEP) have formed such a partnership for the renewal of AMI’s National Pollutant Discharge Elimination System (NPDES) stormwater discharge permit.

Both AMI and FDEP have realized significant benefits to forgoing the conventional permitting process, in favor of this collaborative partnership. Much of the time and costs associated with the conventional permitting process are reduced, because most of the specific details contained in the permit have been mutually agreed on prior to compiling the initial draft permit. Moreover, post-issuance litigation is obviated. Additionally, the most effective and protective permit results because all options and alternatives have been examined. And finally, there is the benefit of the relationships that develop through this process, as regulators and facility personnel recognize each others perspective and gain respect for the common end that they are both trying to reach. These relationships are a great benefit to both sides, especially when future concerns may arise. The framework for working out a mutually beneficial solution has already been established.

Introduction

We have come a long way since environmental permits were first being issued thirty some odd years ago. I suspect that many facilities felt that they were unnecessary, since they had been operating fine without them in the past. The regulations and permits represented limitations that ultimately added additional costs, and took away from the company’s bottom line. I suspect as well, that in some cases, this set up an adversarial relationship between the regulators and the regulated community, in an “us” verses “them” manner. I believe that though some of this may still exist, that it is certainly in the minority, and more the exception than the rule. I believe that most companies realize that we need environmental regulations and that environmental permits are now just another element of their overall business organization. Regulations and the subsequent specific conditions of the permit establish the guidelines by which a facility may conduct their business and not have a significant detrimental impact to the environment. I suppose that there are some bad actors out there that disregard protection of the environment for the sake of profit, but again I believe that they are in the minority. Most people in general are environmentally conscience, consequently, overall, most companies strive to be environmentally responsible. It is a matter of good business ethics and reputation. One of many permits that a facility, in this case, a shipyard, must have in order to operate, is a stormwater permit. There are a variety of contaminant producing activities, processes, and materials that are essential to the operation of a shipyard, often in areas that are exposed to stormwater. Consequently, Federal and State regulations set guidelines for the proper management of that stormwater by way of stormwater permits. Most shipyards, and other industrial facilities, are subject to permitting under the Federal National Pollutant Discharge Elimination Program (NPDES). In many cases, the permitting and enforcement authority have been delegated to the States.


Historically, when a facility was determined to have the potential for the discharge of contaminated stormwater to an adjacent receiving body of water, they were required to apply for a NPDES stormwater permit. These permits contain certain guidelines for the general management of stormwater including; material and activity best management practices (BMPs), and monitoring requirements. The permits are commonly valid for five years, with the requirement that an application for permit renewal be on file 180 days prior to the expiration of the existing permit. Of course at any time during the life of the permit, if the regulatory agency feels that the permit needs to be revised to provide adequate protection of the environment, they have the option to revise the permit accordingly. This typically occurs if stormwater analytical monitoring data submitted by the facility is determined to be unsatisfactory by the regulatory agency. Subject

The permitting of stormwater discharges from shipyards is a very complex process. Because shipyards are necessarily located directly adjacent to a navigable body of water, there are several unique issues that must be addressed in association with the stormwater permit. In many cases, stormwater management opportunities utilized by land-locked facilities can not be practically implemented in a shipyard. In addition to the constraints of location, the sheer magnitude of shipbuilding and ship repair operations also presents several unique issues that must be addressed in the stormwater permit. Many of the activities and operations conducted in a shipyard are by necessity conducted outdoors, and in many cases while the vessel is still in the water. Work activities in a shipyard also tend to be cyclical and transient. Consequently, the potential for stormwater exposure is quite high. The application of conventional stormwater management “best management practices” (BMPs) can not always be effectively implemented given the size of the facility, the volume of stormwater, and its proximity to the receiving water body. Equally complex and problematical is the development of a regulatory-based stormwater discharge permit. Stormwater discharge regulations are designed to prevent the significant deterioration of the quality of a body of water that receives stormwater run-off from a potentially pollutant source. In many cases, the regulations are of a “one size fits all” variety and are very narrowly defined with regard to allowable pollutant concentrations, monitoring and analysis protocols, and required management activities. This significantly constrains the permit writer and leaves him with little flexibility to address facility specific issues. The conventional permitting process follows the pattern of; facility submittal of the application, agency review to determine completeness, agency request for additional information, facility submittal of additional information, agency review, agency drafting the initial draft permit, facility review, facility submits comments to agency seeking relief from onerous and/or non-applicable permit requirements, agency review – they agree or disagree, facility submits comments to agency seeking relief from onerous and/or non-applicable permit requirements, agency review – they agree or disagree, facility submits comments to agency seeking relief from onerous and/or non-applicable permit requirements, agency review – they agree or disagree, facility seeks judicial relief, a court or administrative review board decides what should be in the


permit, and the permit is issued. One party is certain to be disappointed, often both are, for the permit came at great effort, time and cost to both parties. That is the fundamental flaw in the conventional permitting process. There is however, a resolution to overcoming the constraints encountered by both the facility and the regulatory agency, in developing a permit that meets all the applicable regulatory requirements and is also practical and achievable for the facility. That is “Partnering”, partnering in a collaborative effort, sharing information and ideas toward a mutually beneficial end. Notwithstanding the obvious regulatory implications, the discharge of stormwater from any facility that may be contaminated with the by-products of its operations, has the potential for having a detrimental impact on the environment. A responsible corporate entity should conduct its operations not merely to attain regulatory compliance, but to have the least environmental impact possible. Logically, a facility needs to conform its operations and stormwater management BMPs to meet and/or exceed where possible, the regulatory requirements. In order to do so, the facility must have intimate knowledge of the permitting process and where permitting flexibility exists to fit its facility specific operations. Likewise, until a permit writer has intimate knowledge of the facility lay-out, operations and processes, exposure potentials and existing stormwater management BMPs, he is not equipped to adequately address facility specific constraints in managing stormwater discharges. Most regulatory agencies possess engineering staffs with a wealth of expertise and experience in permitting for many types of industrial facilities. This experience and expertise is indispensable in assisting the facility in orienting its approach toward the most effective stormwater management program for the environment. In addition to the benefit of having a mechanism in place for the sharing of information and strategies, there is the collateral benefit of having a mechanism for “joint problem solving”. Specifically, the Agency and Facility can undertake a collaborative review of the regulations and permitting frame-work to determine if there is any “flexibility” available to address facility specific issues that might not be readily recognized otherwise. As well, the Agency and Facility can review the various options available to address a particular stormwater management problem, and jointly undertake “pilot project” activities together as a “team”, to determine if there is a possibility for a solution. In this “partnering” or “team” arrangement; current BMPs can be evaluated, new BMPs can be tested, the possibility of facility structural improvements can be assessed, optional monitoring techniques can be considered, alternative materials can be investigated, potential treatment methods can be analyzed, etc. In a break from convention, and what is hopefully a step toward a new philosophy and approach in permitting, Atlantic Marine, Inc. (AMI) and the Florida Department of Environmental Protection (FDEP) have initiated a “partnership” for AMI’s NPDES stormwater discharge permit renewal. We call it “Partnering for the Environment”. This partnership, in part, came about as a result of FDEP’s review of stormwater analytical monitoring data that they had determined to be unsatisfactory. FDEP subsequently requested that AMI meet with the Department to discuss the possibility of revising the permit to include numeric effluent discharge limits. During the meeting FDEP expressed their concern over what they considered to be high concentrations of copper and zinc in AMI’s discharges, that they exceeded the State of Florida Surface Water


Quality Standard, and that AMI was in violation of its NPDES stormwater permit for the discharges. AMI contended that since there were presently no numeric effluent limits in the permit, that they were not in violation of its permit, and further, that the mere placing of numeric limits would not result in an automatic improvement in the quality of its stormwater discharges. In fact, that to place numeric limits at present would only result in AMI being in violation during the next storm event. That would force the agency to have to take action against them, either by fining the facility or requiring that they cease and desist the discharge of stormwater. Atlantic Marine would also be subject to the potential for third party liability litigation, as would FDEP if they did not take action. During the ensuing discussion there was a fundamental disagreement on what numeric limits, if any, were appropriate, although it was unilaterally agreed that improvement in stormwater management was necessary. FDEP noted that the Atlantic Marine permit would be expiring within a year and requested that in lieu of numeric effluent limits that AMI submit a plan on how it intended to improve in the area of stormwater discharge quality. In response, AMI proposed to put together a “stakeholder team” to analyze in detail every aspect of facility stormwater management, including; current processes and materials utilized that may be contributing factors, current best management practices for preventing stormwater contamination, potential facility improvements or engineering controls to reduce exposure, potential operations modifications to minimize or eliminate contaminant generation, and potential alternative materials utilization that contain less or none of the contaminant constituents of concern. AMI proposed that the team include their Environmental Director, Production Manager, Facility Engineer, Industrial Engineer, and various Department Foremen from crafts identified as conducting activities that may be considered potential sources of stormwater contamination. And as partners with equally interest, AMI also proposed to include two members of the FDEP District Industrial Wastewater Division that had decision-making authority. AMI also was represented by legal counsel and were assisted by an environmental engineering consulting firm familiar with their NPDES permit application. FDEP agreed to the plan and to providing two Department representatives to the team, deferring any action on the current permit, rather focusing on developing permit conditions that were most beneficial for protection of the environment and that would practically fit within the operational framework of the Atlantic Marine facility. The proceedings of the individual partnership “team” meetings were facilitated by a third-party non-biased objective facilitator, who had extensive experience in stormwater permitting and was intimately familiar with shipyard operations and processes.

Conclusion

There are enormous advantages to working out the details of the permit prior to initiating the permit drafting process, notwithstanding the elimination of potential litigation. A collaborative, systematic and comprehensive investigation of all of the aspects of a facility that have the potential for impacting stormwater discharges is essential prior to commencing to draft the permit. Additionally, the sharing of concerns and ideas gives both the facility and the regulatory agency a feel for the others perspective, and in many cases results in the development of an innovative solution. These potential solutions may be the results of collaborative pilot projects, or from the evaluation of the effectiveness of alternative BMPs. The Agency and Facility are


also both benefited by the joint examination of the facility’s on-site operational, logistical, and/or structural constraints and by reaching agreement as to “what is” and “what is not” practically achievable and economically feasible to implement. Moreover, by working through all of the contentious issues up front in a collaborative partnership, by the time that the first draft of the permit is written, both sides are already essentially in agreement with the contents, thus avoiding the litigation that is often quite common in “after-the-fact” permit negotiations associated with the “conventional” permitting process. Finally, there is the benefit of the relationships that develop through this process, as regulators and facility personnel recognize each others perspective and gain respect for the common end that they are both trying to reach. These relationships are a great benefit to both sides, especially when future concerns may arise. The framework for working out a mutually beneficial solution has already been established Atlantic Marine and the Florida Department of Environmental Protection have discovered that “Partnering for the Environment” is the most constructive manner in which to approach the permitting process. It ultimately saves both the facility and the agency, time, money, and a great deal of controversy.

1

11/17/2001Southern States Environmental Conference 2001 Shipyard Track 1


Permitting of Shipyard Stormwater Discharges

“Partnering for the Environment”

11/17/2001Southern States Environmental Conference -Shipyard Track 2

Introduction

• Businesses recognize that Environmental Regulations are necessary.

• Environmental Permits are the mechanism through which “performance guidelines” are established.

• Permits may be Federal or State.

2


N.P.D.E.S.National Pollutant Discharge Elimination System

• Typical Permit Duration of 5 years

• Reapplication for Renewal must be file 180 Days prior to expiration of existing.

• Regulatory Agency may revise/modify the Permit at any time if regulations or standards change or to provide additional protection to the environment.


ShipyardsNon-Typical Industrial Facilities

• Located by Navigable Body of Water.

• Usually Large in Area - Creating Large Volumes of Stormwater to Manage.

• Many Outdoor Operations - Creating Many Opportunities for Stormwater Exposure.

• Operation are Fast-paced, Cyclical, Transient, and very Diverse.

3


ShipyardsNon-Typical Industrial Facilities

• Conventional Stormwater Management “Best Management Practices” (BMPs) for controlling Stormwater Discharges at other types of Industrial Facilities, may not necessarily be “effectively implemented” at a Shipyard.


NPDES Regulations & Permits• The Regulation is “One Size Fits All”.

• The Regulation is Very Narrowly Defined• Pollutant Concentration Limits• Monitoring and Analytical Protocols• Stormwater Management Requirements

• Consequently, the Permit Writer has very little “Flexibility” to address Facility Specific Issues.

4


Conventional Permitting Process• Facility submits Application

• Agency Reviews Application for Completeness

• Then - The agency request for additional information, facility submittal of additional information, agency review, agency drafting the initial draft permit, facility submits comments to agency seeking relief from onerous and/or non-applicable permit requirements, agency review – they agree or disagree, facility submits comments to agency seeking relief from onerous and/or non-applicable permit requirements, agency review – they agree or disagree, facility seeks judicial relief, a court or administrative review board decides what should be in the permit, &

• The Permit is Issued• At the Expense of a great deal of “Time, Money, and Controversy”.


Solution to Problems of Conventional Permitting Process

• “PARTNERING” - Facility & Agency• A Collaborative Effort (Teamwork)• Sharing Information & Ideas• Joint Examination of all contributing aspects• Joint Review of all Options and Flexibility• Learn the Constraints of the “Other Side”.

5


Partnership Benefit to Agency

• See First-Hand the Facility Operational, Logistical, and/or Facilities Constraints.

• Can Measure the Effectiveness of the Current BMPs.

• Participate in “Pilot Projects” toward Stormwater Management Improvements.


Partnership Benefit to Facility

• Learn where “Flexibility” in Permitting “Exists” or “Doesn’t”.

• Utilized the “Expertise” and “Experience” of the Agency. (Multi-Industrial)

• Demonstrate Actual Compliance Constraints to the Agency.

6


Partnership “Ground-Rules”• Facility Agrees to go “Beyond Compliance”,

where “Agreeably Feasible”.

• Agency Agrees to Disclose All Permitting “Flexibility” Available.

• Facility Agrees to Allow Agency Complete Access. (to facility and records)

• Agency Agrees to only Address/Disclose “Stormwater Applicable Issues”.


Partnership “Ground-Rules” (continued)

• All “Team” Activities are “Confidential”.

• All Information is “Shared”.

• All Ideas are “Tried”.

• The “Team” acknowledges “Successes” and “Failures” as a “Team”.

7


Conclusion - What Kind of Permit can you get through “Partnering” ?

• A “Well Informed” Permit• All “Options” and “Flexibility” has been explored.• The Permit provides Acceptable Protection of the

Environment. (possibly “beyond” compliance)• The Permit is actually “achievable” for the Facility.• The Permit addresses “Facility Specific”

Constraints & Solutions



• A “Mutually Agreeable” Permit• All of the Details have been worked out prior

to the “first draft” - Eliminating the Time and Cost of “Comment Exchange”.

• Avoid having a Court or Administrative Review Board decide Permit Contents, thereby Avoiding Additional Time & Costs.

8



• A “Legally Protective” Permit• The potential for Third-Party Liability

Litigation is eliminated/reduced.• For the Facility, for Failure to Comply with

Permit Conditions that are Beyond their Ability.• For the Agency, for failure to issue a Permit

that Adequately Protects the Environment.


Questions ?• Answers

• Comments

• Rebuttals

• Boos & Hisses

• Throwing of Rotten Tomatoes


1

Shipyard Stormwater Pollutant Sources and Loading Dana M. Austin

President Dana M. Austin Environmental Consulting, Inc.

Presented at the 11th Southern States Annual Environmental Conference


September 2001

Abstract

Various shipyard operations and processes can be the source of pollutants found in shipyard stormwater discharges. It is important to identify the pollutant types, their potential sources and estimate the loading from these sources in order, to determine where Best Management Practices to control the discharges can be applied.

This paper uses common shipyard operations and processes as examples to demonstrate how to determine the types of pollutants generated, estimate their loading in stormwater, and perform a pollution pathway analysis. A structured format has been developed in order to evaluate the sources, pathways and discharge points for shipyard stormwater pollutants. This evaluation process can be applied by shipyard environmental managers for their specific facility, location, operations and processes. Based upon this evaluation, Best Management Practices can then be developed and implemented to specifically target those sources and pathways that are the greatest contributors to stormwater pollution.

Introduction

The management of shipyard stormwater discharges in order to reduce pollutant loading in the most practical and cost-effective manner requires an organized approach in determining the source, loading and pathway of the pollutant. We begin by systematically determining the sources and estimating their magnitude to the pollutant load, and then prioritize the sources according to their respective contributions. Pollution pathway analysis can then be applied to determine the most appropriate type(s) and location in the pathway in order to apply controls to reduce or eliminate the discharge. In this manner, the shipyard will achieve a greater benefit for the resources invested.

Sources of Shipyard Stormwater Pollutants

Sources of pollutants in shipyards that may ultimately end up in stormwater discharges are generally derived from operations and processes conducted in the out-of-doors. The general nature of shipyard operations usually requires industrial processes to be conducted at the location of the ship, rather than the ship being taken to the process. Additionally, as most shipyards have the ability to position a vessel in different areas (piers, berths and docks) within the yard, many industrial processes are conducted in different areas, at different times. For these reasons, it is often difficult for shipyards to “pin-down” the precise sources of stormwater pollutants at any given time, and to successfully apply applicable Best Management Practices to reduce or


2

eliminate the discharge.

The most effective, and common sense method of determining the potential sources of shipyard stormwater pollution is to examine all industrial operations and process that do, or could, occur within an area of the yard. For smaller yards, this area could encompass the entire site. For larger yards, with multiple stormwater drainage areas, it is typically easier to break the yard down into areas based upon the rainfall drainage patterns. Once these drainage pattern areas1 are defined, the industrial operations and processes that do, or could, occur in the areas can be identified. In identifying the operations and processes that occur within a given area, it is important to prepare as complete a list as possible, including transient and/or infrequent processes. Without a complete list, it is possible that potentially significant sources of pollutants could be overlooked. Additionally, it is important to identify, and eliminate from consideration, operations and processes conducted within the area that are not sources of pollutants.

Shipyard Sources of Pollutants

Operations and Processes Sources Operations are defined as a series of processes that are conducted in a specific sequence for the purpose of achieving a particular result. For example, “Surface Preparation” operations may be conducted using a dry-abrasive blasting process, to achieve the result of a clean and profiled surface upon which a coating can be applied. The process of dry abrasive blasting can be reduced to a series of individual steps or phases in as fine a level of detail as necessary for the analysis being conducted. The steps or phases in any operation can be shown graphically in the form of a process flow chart, including the process inputs (materials) and outputs (products, and waste). Process flow charts are particularly useful in identifying emission points in the operation that can be used to evaluate potential and actual sources of pollutants. An example, a process flow chart for dry abrasive blasting is shown in Figure 1.0 and 1.1. The flow chart indicates both the steps in the process, and where in those steps pollutants may be released to the environment.

Examples of some common shipyard operations and processes are provided in Table 1 below:

Table 1: Shipyard Operations and Processes

Operations Processes Dry abrasive blasting Hydro washing Ultra High Pressure Water Jetting

Surface Preparation

Solvent Cleaning

Bush and roller coating application – exterior and interior of ship. Spray application of coatings - exterior of ship.

Coating Application

Spray application of coatings - interior of ship.

1 The drainage patterns within a facility can often be defined to a good first order approximation by simply observing the water flow during a rain event. Keep in mind that the intensity of the rainfall (volume of rain/time) can affect flow patterns. Due to hydraulic factors, intense rainfall can result in a different drainage pattern than a light rainfall.


3

Spray application of coatings - small parts Flame spray

Cutting, burning of metal structures or parts. Brazing of metal structures or parts

Welding of metal structures or parts Metal Working

Grinding of metal surfaces.

Fabrication of piping systems Installation of piping systems Modification of piping systems Repair of piping systems

Pipefitting

Pressure testing of piping systems

Remove structural materials Repair structural materials Installation of structural materials

Shipfitting

Layout and Fabrication of structural materials

Manufacture of sheetmetal items. Modification of sheetmetal items. Repair of sheetmetal items.

Sheetmetal

Assembly of sheetmetal items.

Manufacture of machine items. Modification of machine items. Repair of machine items.

Machining

Assembly of machine items.

Cutting of wood products. Milling of wood products. Sanding of wood products. Preserving of wood products.

Carpentry and woodworking

Assembly of wood structures.

Removal of insulation materials. Insulation

Installation of insulation. materials.

Most shipyards conduct similar operations and processes, varying from each other in the scale of the operations. Other differences will exist between processes conducted in shipyards such as types of materials used, locations in the shipyard where a specific step in the process may occur, and the sequence in which the process steps are performed. There may also be some degree of


4

variation in how a process is conducted in the same facility, often depending on the required results of operation. For example, dry abrasive blasting may be conducted using coal slag on one type of surface, and steel grit on another. These variations in the process must be taken into account and evaluated to determine the types and emission points of the pollutants generated in each of the process variants.

Non-Process Sources Not all sources of pollutants in the shipyard will be from industrial operations and processes. While we tend to focus our efforts on the current operational activities in the yard, it is important to remember that there may be other Non-Process sources that are large in comparison to active processes.

For example, stormwater may be contaminated from existing pollution in the soil on site, as a result of previous industrial activities no longer conducted. Atmospheric deposition of pollutants from off-site locations onto the facility may also be a significant source. In some situations, stormwater “run-on” to the site that is already contaminated may contribute to elevated levels in your facility’s discharges.

Just because a pollutant can be measured in your facility’s discharge does not mean all of it originated from the facility’s sources. If you cannot determine an on-site source for a pollutant in your stormwater, or if there appears to be higher concentrations of a pollutant than can be rationalized from only on-site sources, investigate potential off-site sources of pollution that may be contaminating your stormwater.

Pollutant Loading Estimates

The next step in evaluating stormwater pollution is to estimate the potential source loading of the pollutants. This is, in many cases, the most difficult phase of the analysis to perform accurately. In most instances, you will not have empirical measurements of pollutant emission rates from the actual processes. However, even an order of magnitude estimates can play an important role in prioritizing sources based upon their potential contribution to the total load in the stormwater discharge. When considering the application of controls on a source to reduce or eliminate the pollutant load, whether these are control devices, Best Management Practices or other mechanisms, it is vital we do not waste the facility’s resources in applying controls that will not have the desired effect of reducing the loading. Whether the goal is to achieve an improvement to environmental quality, or meet an established water quality standard, it makes the most sense to control those sources that are actually contributing to the majority of the loading.

Loading estimates can be done using process mass balance equations and emission factors for the pollutant(s) of interest. In those instances where emission factors are not available for the process under evaluation, you will need to use “characteristic knowledge” of the process to make a best estimate. Testing may ultimately be required to determine if your estimate is accurate.

Using dry abrasive blasting in a blast pit as an example, we would assemble the following information necessary to estimate the annual loading of copper in stormwater discharges.

Process Material Input: Copper Slag

Average Annual Usage of Copper Slag in Blast Pit: 100 tons


5

Particulate Matter Emission Factor for Copper Slag: 10 lbs PM/ton used

Average Concentration of Copper in Copper Slag Dust: 50 ppm

Assumptions: (1) All dust emissions from blast pit settle to ground surfaces on site.

(2) All dust on ground surfaces is washed into facility storm drains during storm events.

Based upon the above data and assumptions, we can estimate total annual load of copper from this specific source as follows:

(100 tons Copper Slag/year) X (10lbs PM/ton used) = 1,000 lbs PM/year

(1,000 lbs PM) X (50 ppm Copper) = 0.05 lbs Copper/year

Note that this estimate of the annual load from this specific source is not a true estimate of the discharge to the environment, and should not be used as such. Its only real “value” in this analysis is to provide a value (in this example, 0.05 lbs Copper/year) that can be compared to other source load estimates so as to determine which may be the largest contributors of this pollutant to the overall stormwater discharge from the facility, or a specific outfall. In this manner, it is possible to make a reasonable determination as to whether the implementation of controls will actually result in some incremental benefit to the environment. In other words, don’t waste your time and the company’s money implementing controls on sources that would not result in a beneficial consequence.

Note that loading estimates are always given in units of mass/time, such as lbs/year or grams/seconds. When prioritizing sources, as explained above, all the loading estimates must be expressed in the same units to make a valid comparison. As the shipyard is a “job-shop” production environment, bear in mind that not all source processes may be occurring on a regular basis. Don’t lose sight of the fact that a process that only occurs over a few day period, a couple of times per year, may in fact be the largest potential contributor of a pollutant over an annual period. It is best to keep your loading estimate time periods relatively long (at least a year) to ensure all possible significant pollutant contributors are identified and evaluated. Brainstorm your initial list of operations and processes, then confirm, correct and revise using direct observation in the field and interviews with the shipyard craft personnel.

Stormwater Pollution Pathways

For a pollutant to be discharged to the environment there must be a “pathway” from its point of generation to its discharge point. A pollution pathway is a series of steps, usually involving the physical transport or movement of the pollutant, from its point of generation, to one or more of the environmental media (air, land and water), either within or outside of the facility. Pollution pathways are analyzed to determine how best to reduce or eliminate the amount of pollutant (loading) ultimately discharged to the environment. If the generation of the pollutant cannot be completed eliminated, the next step is to control or “block” the pollutant’s pathway to the environment.

Stormwater is both an environmental media (which may become contaminated with a pollutant), and also a step in the transport pathway to other media (surface waters and sediments). While some pollution pathways controls can be applied to contaminated stormwater prior to its


6

discharge from the facility, it is often easier, less expensive and more practical to prevent the contaminate rather than divert, contain and treat stormwater in any significant qualities.

Like operations and processes analysis, pollution pathway analysis is performed by determining the specific sequence of steps or paths a pollutant will take from its origin to its discharge point. Additionally, the actual and/or potential transport means are also identified from each step to the next. These steps and transport means can then be represented as a flow diagram that is useful in determining how and where controls can best be applied to block the pathway.

As pollution pathways represent actual physical routes from the point of generation to the point of discharge to the environment, they are strictly dependent upon the location within the facility in which the process (or portion of the process) is being conducted. As an example, the pollution pathway to the surface water of dust generated from outdoor abrasive blasting would be different if the blasting is conducted in a dry dock, as compared to a blasting pit. In the drydock, the dust emissions are directly emitted to the air, followed by direct deposition to the surface water. In the blast pit, dust may first be emitted to the air, followed by deposition to the ground within the facility, and then transported by stormwater to a drain where upon it is discharged to the surface waters from an outfall. In this example, the same process generated the same emissions, but the location of the activity in the shipyard resulted in completely dissimilar pathways to the same media. As all shipyards differ in respect in their physical layout, pollution pathways must be analyzed using facility specific data. It is also necessary to conduct a separate pathway analysis for each process emission point in each location where the process is performed.

An example of a pollution pathway analysis for a hypothetical shipyard dry abrasive blasting operation is shown in Figure 2.0 and 2.1. (Blank pollution pathway forms as attached as Figures 3.0 and 3.1, in event the reader desires to utilize this methodology within their own facility.) As illustrated in the example, a pollution pathway flow chart begins at the point of discharge of the emission, and ends at the point where the pollutant is discharged to the media. In this example, the pollutants carried in the dust of abrasive blasting operations end in both the surface waters and sediments. If additional steps in the flow chart were required, one would merely attach as many pages as necessary to complete the chart.

Pollution pathway analysis may be performed on any of three bases: Processes, Areas, or Pollutants. In the first instance, the analysis is performed for all processes that occur in the shipyard regardless of the location in which they are conducted, or what pollutants may be generated. In the second instance, only those processes that occur within a given area (for our purposes, a stormwater drainage area) are subject to the analysis. Finally, in the last instance, only those processes that generate (and emit) pollutant(s) of concern are subject to the analysis. Each of these approaches is valid, and only depends upon what your specific goals are in performing the analysis. For example, you may be concerned about “high” copper levels measured from a specific outfall of the yard. The most efficient pollution pathway analysis would be to only examine those processes that emit copper in this stormwater drainage area. This would significantly reduce the effort required, and hopefully determine the source(s) of the copper more quickly.

Summary

Stormwater contamination issues in shipyards can be difficult to successful resolve due to the job


7

shop nature of shipyard work and the fact that process pollutant sources must often be moved to different areas of the facility. Due to this fact, stormwater monitoring results can vary widely, both over time and from different monitoring locations. These monitoring results are often of little use in determining the source of the pollutants in stormwater and may result in controls being applied, at great expense, to a source that may only be a small contributor to the overall load. Facilities become frustrated by the fact that resources were expended, while providing no measurable benefit.

This problem can be successfully resolved by the implementation of a standard approach to evaluate pollutant load based upon an operations and processes approach. This methodology evaluates processes as potential sources of pollutants, and prioritizes the sources based upon their estimated contribution to the overall facility (or area) pollutant loading. This is a three-step process that includes:

1. Generating a list of operations, their component processes occurring within the shipyard, and a determination of the potential pollutants emission points in the process;

2. Determination of pollution pathways from the point of emission to ultimate discharge to the environment medias, and;

3. Estimating the loading (mass/time) for each pollutant of concern from each emission point of each process being evaluated. Prioritize the sources based upon their relative contribution to pollutant loading.

After the sources have been prioritized, each source can be evaluated to determine the appropriate type and level of control that can then be implemented to eliminate or reduce the pollutant emissions.

Fig

ure

1.0

Fig

ure

1.1

Dry

Ab

rasi

ve B

last

ing

Em

issi

ons

Poi

nts

M

ater

ial I

nput

: Cop

per

Sla

g ab

rasi

ve

Em

issi

on P

oin

t F

low

Ch

art

No.

E

mis

sion

Typ

e (s

) P

ollu

tan

t T

ype(

s) o

f C

once

rn

Com

men

ts

Loa

d S

lag

into

S

tora

ge S

ilo

1 D

ust,

Spi

llag

e M

etal

s, P

M

Met

als

in v

irgi

n co

pper

sla

g ge

nera

lly

have

a lo

w s

olub

ilit

y in

w

ater

. E

F f

or d

ust e

mis

sion

s ca

n be

es

tim

ated

fro

m s

ieve

dat

a. S

pill

age

of m

ater

ials

dur

ing

tran

sfer

ge

nera

lly

rem

ains

in a

rea,

but

may

be

trac

ked

to o

ther

are

as o

n th

e ti

res

of r

olli

ng s

tock

. L

oad

Sla

g in

to T

ruck

s fr

om S

ilo

2 D

ust,

Spi

llag

e S

ame

as A

bove

S

ame

as A

bove

Tra

nspo

rtin

g S

lag

to

wor

k ar

ea

3 S

pill

age

from

truc

k S

ame

as A

bove

S

ame

as A

bove

Loa

ding

Sla

g fr

om

truc

k to

hop

pers

4

Dus

t, S

pill

age

Sam

e as

Abo

ve

Sam

e as

Abo

ve

Loa

d S

lag

into

bl

asti

ng p

ots

5 D

ust,

Spi

llag

e S

ame

as A

bove

S

ame

as A

bove

Bla

stin

g op

erat

ions

6

Dus

t, sp

ent a

bras

ive

Met

als,

PM

, spe

nt

abra

sive

Coa

ting

rem

oval

may

add

new

, or

incr

ease

load

ing

of m

etal

s in

dus

t an

d sp

ent a

bras

ive.

The

am

ount

of

wat

er s

olub

le f

orm

s of

met

als,

de

rive

d fr

om th

e co

atin

g be

ing

rem

oved

may

incr

ease

d S

pent

abr

asiv

e cl

ean

up

7 D

ust,

spen

t abr

asiv

e w

aste

S

ame

as A

bove

S

ame

as A

bove

Tra

nspo

rt o

f sp

ent

abra

sive

to s

tora

ge

area

8

Dus

t, S

pill

age

Sam

e as

Abo

ve

Sam

e as

Abo

ve

Fig

ure

2.0

Dat

e:__

____

____

___

Pag

e __

of _

_D

ire

ct

Dis

ch

arg

e t

o A

ir

Gro

un

d S

urf

ac

e o

f S

hip

ya

rd

Sto

rm W

ate

r D

rain

(s)

Sto

rm W

ate

r O

utf

all

(s)

Su

rfa

ce

Wa

ters

Se

dim

en

ts

Gra

vit

y D

ep

osi

tio

n

Atm

. W

ash

Ou

t

Sto

rm W

ate

r F

low

Pro

ce

ss W

ate

r F

low

(s)

Sto

rm W

ate

r F

low

Sto

rm W

ate

r F

low

Pro

ce

ss W

ate

r F

low

(s)

Pro

ce

ss W

ate

r F

low

(s)

Gra

vit

y D

ep

osi

tio

n

Oth

ers

(?)

Fig

ure

2.1

P

ollu

tion

Pat

hway

Ana

lysi

s –

Dry

Abr

asiv

e B

last

ing

O

pera

tion

: S

urfa

ce P

repa

rati

on

Pro

cess

: D

ry-a

bras

ive

blas

ting

Loc

atio

n:

Bla

st P

it

Em

issi

on P

oint

: D

irec

t to

air

from

sub

stra

te b

eing

cle

aned

.

Mat

eria

l Inp

uts:

C

oppe

r S

lag,

exi

stin

g co

atin

g be

ing

rem

oved

, and

met

al s

ubst

rate

.

Des

crip

tion

of

proc

ess

step

or

poin

t re

sult

ing

in e

mis

sion

s:

Cop

per

slag

is a

ccel

erat

ed, u

sing

com

pres

sed

air,

and

impa

cted

aga

inst

sub

stra

te b

eing

cle

aned

.

Typ

es o

f P

ollu

tant

(s)

Rel

ease

d:

Par

ticu

late

mat

ter,

met

als

and

poss

ibly

oth

ers

depe

ndin

g on

abr

asiv

e us

ed a

nd s

ubst

rate

cle

aned

.

Fig

ure

2.1

Pol

luti

on P

athw

ay A

naly

sis

Ope

rati

on:

Pro

cess

:

Loc

atio

n:

Em

issi

on P

oint

Mat

eria

l Inp

uts:

Des

crip

tion

of

proc

ess

step

re

sult

ing

in e

mis

sion

s

Typ

es o

f P

ollu

tant

(s)

Rel

ease

d:

Fig

ure

2.1

Dat

e:__

____

____

___

Page

__o

f __

1


Managing Shipyard Stormwater DischargesShipyard Pollutant Sources

and Loading


Shipyard Stormwater Pollution

2


Shipyard Stormwater Pollution

• Difficult to characterize.

• Monitoring information often is not informative.

• Pollutants tend to be a “moving target.”

• Is there a way to get your arms around the problem?


Shipyard Pollutant Sources and Loading

• A systematic method to characterize sources of pollutants and estimate their loading.– Can be applied to any type of discharge.

• Stormwater• Process waters

3



• Analytical tools, that when properly applied can:– Identify the major sources of pollutants.

• By Type• By Area• By Discharge

– Prioritize pollution control efforts.



• Benefits– Identification of appropriate and effective BMPs or

other pollution control processes.– Reduce or eliminate the discharges of pollutants of

concern.– Reduced costs to implement pollution control

measures.– Increased ability to meet environmental and

compliance goals.

4



• Pollution Pathway Analysis– Identify sources of pollutants.– Estimate potential loading of pollutants.– Determine potential pathways of pollutants to

the environment.



5



• Shipyard Sources of Pollutants– Operations

• A series of processes perform in a specific sequence necessary to obtain a specific result.

– Non-process sources• Sources of pollutants derived from non-

shipyard processes.



• Source Identification– List the Operations.– Flowchart the processes for each operation.– Identify the potential sources of pollutants for

each processes, for each type of pollutant.

6





• Estimate Pollutant Loading– Necessary to prioritize sources of pollutant(s)

of concern.– Identifies what sources should be controlled.– Eliminates non or insignificant sources from

consideration.

7



• Estimate Pollutant Loading– Mass balance equations.– Pollutant Emission Factors.– Characteristic Knowledge of Operations and

Processes.



• Pollution Pathways– How does the pollutant get to the

environment?• Physical pathways• Transport Mechanisms

– Each step in the pathway must be identified.

8



• Pollution Pathways– Pollution Pathway analysis can be used to

determine where Best Management Practices can be most effectively applied.

– Where in Pathway can be pollutant be “blocked” from entering the environment?

Pollution Pathway Analysis Operation: Surface Preparation – Coating removal

Process: Dry Abrasive Blasting

Location: Graving dock

Emission Point Air borne dust derived from blasting operations

Material Inputs: Abrasive, coating being removed

Description of process step resulting in emissions

Compressed air dry abrasive blasting

Types of Pollutant(s) Released: Copper

9

Date:_____________Page __of __Dust emission to air

Gavity Deposition

Surface of Ground

Storm water flow

Storm drain

Storm water flow

Storm water outfall

Surface Waters

Discharge from outfall

Gavity Deposition

Sediments



10



• Pollution Pathway Analysis– Document your analysis and progress

• Provides important metrics to determine progress in achieving goals.

• Demonstrates “Good-Faith” effort in compliance with permit requirements.

• Necessary analytical tool to achieve goals.



• Pollution Pathway Analysis– Adaptable to Shipyard “Job-Shop”

environment.– Reduces effort spent on implementing

controls on sources that are not significant contributors.

– Reduces the Shipyard’s impact on the environment.

11


Hydro Blasting and Water-Jetting in the Marine Construction Industry “Renewing America with Renewable Resources”

By Lydia M. Frenzel, Ph. D.

Advisory Council, San Marcos Texas Prepared for Southern States Environmental Conference, September, 2001

www.advisorycouncil.org

Abstract: Everyone talks about clean air and clean water. The marine industry and coatings removal is an industry driven by tradition and the natural response is that change will be more expensive and difficult to do. Since 1985, waterjetting has moved from a curiosity in coatings removal to become a reality. No one feels comfortable with change. Forces that drive companies away from traditional dry abrasive blast cleaning are safety and health, economics, environmental, and performance issues. The convergence of the thought processes by the shipyard or contractor, the owner, and the coatings manufacturer have to combine with the driving forces to make evolution possible. We will examine how this continual improvement evolution came about and what the change means to the marine construction industry in terms of waste minimization and pollution prevention. We will look at the volumes of water produced by waterjetting compared to storm water run-off.

Introduction: I am going to say upfront: A lot of this paper is derived from a presentation by Norm Morris at the “Clean Water Safe Harbor” 2000 meeting in Houma Louisiana sponsored by Texan Natural Resource and Conservation Commission, Louisiana Dept. of Environmental Quality, and EPA Region VI Pollution Prevention Roundtable. Norm Morris, Delta Pollution Controls, Washington, works with major water blasting sites to design and build water collection and recycling systems for portable use, and on-site and in-plant stationary systems. Morris’s full text and presentation are available on two cd’s - “Clean Water- Safe Harbor” - which contain the written text and actual full verbal presentations. (Advisory Council, “Clean Water Safe Harbor,” May, 2000, Houma, LA, proceedings, p. 124-127 ) There exists a common feeling that the production side of a process is always interested in faster throughput while the environmental personnel are slowing the job down and adding to the costs. “Clean Water - Safe Harbor” is designed to bring these two points of view together to formulate methods which are economical, fast, minimize waste, reduce air and general pollution, and that meet the technological demands of coatings performance. Make no mistake. The modern contractor and facility owner has to be totally aware of the environmental regulations whenever a waterjetting project is being planned. Waterjetting and Water Abrasive techniques are used for asbestos and hazardous paint removal projects because water wets the airborne particles so they do not float in the air. Personal monitoring shows levels of respirable lead to be less than the action limit. Environmental regulations are a fundamental driving force in the modern maintenance world. Environmental considerations have changed the face of coatings removal! (L. M. Frenzel and Jonell Nixon, “Comparison of Federal, State, and Local Regulations in Lead Abatement Planning,” SSPC, 1994, 7th Annual Lead Conference; L.M. Frenzel, Cleaner Times, Lead Based Paint, Pt. 1; Legal Requirements for Removal, p.28, July, 1996; Pt. 2 August, 1996)

1

This presentation will include two case histories. Both are open gun methods on complex structures involving toxic lead based paint. One involved collection and recirculation; the other was a pass-through system. What is common to each of these projects is that the viewpoints of the OWNER, COATINGS MANUFACTURER, and CONTRACTOR all had to agree. Now, let’s concentrate on the wastewater aspect of a waterjetting project.

Discussion: When developing a plan to treat wastewater generated from water blasting or wet abrasive blasting operations there are four basic things that must be closely evaluated. A. How do I collect this stuff I am generating? B. How much wastewater am I going to generate? C. What am I going to do with the water after I treat it? D. How am I going to treat it to meet the discharge requirements? WASTEWATER COLLECTION

If the application for instance is a dry dock operation that is cleaning ship hulls or removing paint from ship hulls, the first thing that has to be done is to come up with a method of capturing the wastewater being generated. Large dry docks are normally sealed with steel plate with a crown in the middle and trenches on each side. The dock master is asked to lift the dock so there is a slight slope to the dock so all the water will run to the shore end of the dock. Collection sumps are placed at the end of the dry docks that are plumbed together to form a common sump. A large drain valve is placed in the sump to drain the dock when lifted and for rain diversion.

Your next step is sizing your pumps and holding tank. You have to make the decision whether this is just for the effluent water from the jetting or if it will include the storm water runoff also.

Typically a pump(s) is placed in the sump to handle the wastewater being generated at normal washing rates. The pump(s) is sized depending on how much water is generated during hull blasting.

WATER GENERATION & COLLECTION

Most Waterjetting operations collect the water as it is generated. The water is filtered or placed in a baffle tank with weirs to allow solids to filter out.

However, let’s suppose that you plan to hold the waterjetting effluent and also run-off

rainwater. Now comes the sizing of the holding tank used prior to treatment. You must calculate the surface area of your dry dock and see how much water will be

generated in a rain event coupled with your pump usage. The holding tank must be large enough to conservatively handle at lease two rain events plus pump water from blasting. RAIN WATER RUNOFF

If a dry dock is 600' X 100" for instance, 1" of rain will generate:

600ft long X 100 ft wide X 1 ft deep = 60,000 cu/ft per foot

60,000 cu/ft per ft / 12 inches per ft = 5000 cu/ft per inch

There are 7.48 gallons per cu ft thus:

2

5000 cu/ft X 7.48 = 37,400 gal per 1" rain event WATERJETTING RUNOFF Let’s estimate conservatively that the contractor will run 2 UHP Waterjetting pumps for 16 hours non-stop. Then: Ultra High Pumps generate 4-6 gal/min x 60 min/hr x 16 hrs = 5760 gal You can see this is small compared to the storm water run-off. In actual fact, waterjetters have their guns on for about fifty-percent of the time. TOTAL RUNOFF FOR RAIN WATER AND THE RAIN STORM. Let’s sum the two numbers together:

Storm Blasting so 37,400 x 2 + 5760 = 80,000 gallon tank

The treatment system should be sized to treat that water in 24 hrs is you are planning to collect both storm water and waterjetting water. If you want to empty the tank then the pump size to accommodate both the storm runoff and the blasting water is: 80,000gal / 60 min/hr / 24 hrs/day = 55 gal/min to empty tank in 24 hrs. These are some rough calculations that you might use to get an idea of sizing. The treatment system for recirculating Waterjetting is generally designed for filtration of the larger particles, followed by pre-settling solids in a settling tank, and, depending on the requirements for recycling or disposal, filtering with 2 micron filters- to protect the pump. WHEN I TREAT THIS WATER, WHAT DO I DO WITH IT?

One of the major costs involved in a treatment system is how low the discharge contaminate numbers are that must be met. You now have to look for options for discharging the treated wastewater. Each of these options will have different discharge criteria. Some of the options typically are: 1. Co-mingle with current industrial wastewater followed by Discharge to Public Treatment Works - Best Option 2. Discharge to surface such as sprinklers for vegetation - Tighter limits 3. Discharge to Storm Water retention Pond - Tighter limits still 4. Discharge back to river or sound - Tightest limits of all 5. Recirculation DISCHARGE TO POTW

POTW's treat the water again on the way to its discharge point and typically have a less stringent limit to meet. DISCHARGE TO SURFACE SUCH AS SPRINKLERS

Discharge to sprinklers is sometimes an option in warmer climates. This option is more generally used in storm water runoff than in effluent blast water.

State regulators are typically fond of applications where the water can be reused rather than discharged. These limits are typically tighter than POTW discharge, but still sometimes are as high as 1 ppm of copper which is not as difficult as discharging to the river or sound.

3

DISCHARGE TO STORM WATER RETENTION This option is not used for blast water runoff. Some locations have storm water retention

ponds that the surface water from their site runs into and seeps into the ground. These limits are typically similar to the standards of the sprinklers, but can be more stringent on the discharge requirements if the regulator deems so. DISCHARGE BACK TO THE RIVER OR SOUND

Most of the time, when the solids are removed from the effluent blast water, the chemical characterization is as good as the initial water from the tap. However, it is still difficult to get regulators to allow discharge back to a natural body of water. In fact, it is almost impossible. This standard typically could not be met by the water coming out of your wash down hose. This limit is extremely difficult to meet and would take a much more sophisticated treatment system. System cost coupled with technical expertise to run the system really does not make it a practical option. However, it has been done, by being allowed to utilize a mixing zone in the river prior to river discharge. This must be worked out with the local regulation authorities. RECIRCULATION

When first looking at it this seems the best option because you don't have to get permits or worry about meeting discharge limits. However in reality this may the most difficult of all. Ultra High Pumps require water of very high purity unless you like buying spare parts. In a closed loop system there are salts for instance, that accumulate in the water such as salt (sodium) that comes off the hull in the organic growth. Also there is oil and grease that comes off the hull. The salt and oil level continues to build which causes problems both to the pump and subsequent coatings performance. Contaminants that adversely affect coatings performance need to be monitored. The US Navy paid for development of a closed-loop system integrated into the “SHIP ARMS” that has been in use since 1994. In November, 2000, Jetech Inc. showed a recirculation system for Ultra High pumps. Companies install recirculating systems on stationary plant sites.

The current thought is that it is less costly and conservative of the pump to do a one-pass flow, remove solids, and send it to POTW. Ultra-High Pressure Waterjetting (UHP WJ) is frequently used on lead based paint jobs. Settling can be very effective. On the Comal Power Plant involving 420,000 square feet lead based paint removal, all of the water blast and wash down water went into a large sump over a period of months. The solids settled. After the water was tested for heavy metals by an independent lab using the TCLP method, the non-hazardous 400,000 gallons of effluent water was disposed through the municipal water treatment facility at a cost of $2.79/1,000 gallons (0.003 dollars per gallon) or a total cost of $1,126. Another 10,000 gallons of hazardous waste sludge containing the lead paint was disposed by the owner at an estimated cost of $20,000. For comparison to a dry blast removal, non-hazardous abrasive disposal varies somewhat and costs approximately $65 to $75 per ton in the Virginia area. This calculates to $106,600 for non-hazardous abrasive disposal. It costs about $0.25/pound if the abrasive stream is hazardous for an estimated cost of $820,000. Overall, the volume of hazardous waste was reduced by a factor of 25 in terms of 55-gallon drums. It is estimated that the project saving were over $500,000 by using UHP WJ technology over abrasive blasting. These savings resulted from minimal containment requirements, reduced waste disposal, and high production rates. (Ashworth, Dupuy, Frenzel, WaterJet Technology Association August 2001 Conference, “Turning a Liability into an Asset! The Story of an Old Power Plant”) On the other hand, pumps that operate in the region under 25,000 psi can handle recirculated water. Recirculation is frequently used in those projects.

4

Lead based paint (55,000 square feet) on the Wirtz Dam in Texas was stripped with Waterjetting at 20 to 25,000 psi. The water was taken from the lake and filtered prior to use. Bag filters and settling tanks were used; the water was recirculated. Halfway through the project, the tanks were emptied and refilled. The job was continued. Water was added to make up evaporation loss. The hazardous material was on the filters. The water was disposed as non-hazardous industrial waste. Total hazardous waste was 5 tons. Recirculated blast water in closed- loop systems had leachable lead level of 0.306 microgram/Liter- so trucked to publicly owner water treatment facility. Air monitor average lead level of 7.39 microgram/cubic meter. “the utility was able to save more than $250,000 in materials, labor, and waste disposal costs.”(“Get the Lead Out! Removing Lead-Based Paint on Hydro Plant Structures,” Mark L. Johnson, Lower Colorado River Authority, May 1996, Hydro Review. Lever, Guy, “Hydroblasting permits safe, cost-effective Dam Rehabilitation,” Materials Performance, MP, April 1996, pp 38-41. Lever, Guy, “WaterJetting Cuts Hazardous Waste at Dam,” JPCL, April, 1996, p. 37) HOW IN THE WORLD DO I TREAT THIS STUFF?

After determining how much water will be generated and what you plan to do with it after treatment, you can look at the treatment system. System costs are determined by volume/flow to be treated and how difficult the discharge standards are that must be met.

When looking at treatment systems keep a few things in mind. You are primarily looking at fairly high solids removal of very fine particulate. There may be some metals such as copper, zinc, lead that will actually be dissolved in the water as well. There may be some oils that get in the water from heavy equipment on the dock or incidental bilge water that may have to be addressed. Free oil will float on your holding tank but emulsified oil will not. Some of the WJ pump manufacturers are now exhibiting recirculation systems to meet these requirements.

Here is where Norm Morris and Lydia Frenzel diverge. Morris concludes by talking about a system which is LARGE enough to handle BOTH the blasting and the storm water runoff.

My observation is in the field is that the BLASTING water is handled as it is generated. Most contractor use filters and settling techniques, and very little chemical treatment. They avoid chemical “TREATMENT” because mechanical separation is part of the effluent process. When the word “TREATMENT” is mentioned, some regulatory individuals immediately start thinking about treatment facilities. Equally important, the coatings manufacturers get very anxious when additional chemicals are being added to the water system. They don’t know how the chemicals will affect coatings performance.

Morris says: There isn't much if any oil in the wastewater and it will just plug with solids so don’t just immediately put in a oil/water separator. Since the wastewater stream will have high solids, inline filters such as cartridge or large sand beds will plug very quickly. You want a system to remove solids and also draw dissolved metals from the water as well.

Morris goes on further to describe a system that will work for small boat yards: The most common technology that works well in this area, is the least sophisticated to run, and is the most cost effective to purchase and operate, is a chemical destruct and precipitation system. The wastewater is drawn from the holding tank at the prescribed flow rate determined and sent to a retention tank with constant agitation. A chemical is added to the stream to draw the dissolved metals out of solution to form fine particles in the stream with all the undissolved particulate already present. This tank overflows into another smaller tank where a second chemical is added that has a charge opposite the charge on the fine particulate. This causes all the fine particulate to gather together into a large flake with a much heavier specific gravity causing it to fall rapidly when agitation stops. The stream now flows to a settler, usually a clarifier, where all the particulate falls to the bottom and the clear water migrates to the top. The sludge forming at the bottom is drawn off and pressed under 90 psi into firm cakes for disposal. The clarified top water

5

could pass to a POTW. For more difficult applications it typically would pass though a gravity sand filter to capture any extremely fine particles. The sand filter would not be backwashed often because 99% of the solids have already been removed from the waste stream. If extremely low limits have to be met an ion exchange unit similar to a water softener would be added after the sand bed filter to go after very small amounts of dissolved metals if your trying to meet river standards.

This system can be made to work automatically at flow rates from 10 gal/min to 200 gal/min or more. In small boatyards or on site jobs such as blasting paint off buildings, bridges, or roads batch treatment is often utilized in batch tanks of 350 to 1500 gallon batches. Sludge is dealt with in hanging bags, false bottom dumpsters, or filter presses.

Conclusions 1. Don't kid yourself about how much wastewater you will generate. 2. Be sure you know what you are going to be able to do with the treated water. 3. Design a treatment system that is big enough to treat the amount of waste water you will generate, and be sure its design will remove all contaminates you need to have removed for discharge. 4. The technology exists to strip paint economically with recycling of water from low-pressure water cleaning to ultra-high pressure water jetting. It is possible to run a UHP WJ unit with vacuum recovery on only 50 gallons a day. Acknowledgements: Thanks to Norman Morris, Delta Pollution Control, Preston, WA and to the Advisory Council sponsors which include NLB Corporation, Flow International, Aqua-Dyne, Ingersoll-Rand, UHP Projects Inc., Hydrochem Industrial Services, Holdtight Solutions, Carolina Equipment and Supply, Universal Minerals, and a host of others. It is with their support and cooperation that we are able to attend meetings and continue to disseminate information. References on Presentation Pages Lead in Air- Health Issues- Dan Chute, Dyncorp, “Methods to Control Hazardous Airborne Dust”, National Shipbuilding Research Program, 0509, July, 1999 Baseline Metrics, On-going Study “Ultra-High Pressure Water Blasting -Optimization of the Surface Preparation Process Through Process Reengineering, Ergonomics, and Environmental Improvements”. Presented by Lisa Sovilla, Atlantic Marine, Inc., Maritech ASE Program in January 2001. Taken from NSRP web site. Lydia Frenzel, “ Waterjetting Background, Standards, and Dynamics” September, 2001, MARITECH ASE SP-3, Seattle, WA. Abrasive Injected Water Blasting Economics, see “Cost Effective Alternative Methods FOR Steel Bridge Paint System Maintenance”, CONTRACT NO. DTFH61-97-C-00026, Report III:, “Abrasive Injected Water Blasting for the Removal of Lead-Based Paint,” prepared for The Federal Highway Administration, by: Corrpro Companies Inc., Report: May 19, 1999. Design Requirements were obtained from Todd Pacific in 1995 and used with their permission for general education. Richard Dupuy, “Ultra-High - Pressure Waterjetting for Maintenance Coatings Applications”, JPCL, July 2001, p. 68-75. The Comal Plant is one of their case histories

6

1

Points of View

• Owner

• Contractor

• Coatings Manufacturer

Driving Forces• Environmental

Regulations

• Health and Safety

• Economics

• Performance

2

Ave. Lead In Air (ug/m3) NSRP 0509

680Small Area Touch up- hand/power tools

13,439Open Air Abrasive

4Low Vol. Slurry 9HP Waterjetting3015Containment –recycled metallic media

PEL = 50 ug/m3

Environmental Considerations

•• Clean Air ActClean Air Act

•• Clean Water ActClean Water Act

Occupational Health & Safety ActOccupational Health & Safety ActOSHA

–NIOSH

–Potential Hazards to Workers

3

EPA (initial selection = 43 rules)

Clean Water 7% Clean Air 70%30% Transportation

Clean Air40% other

Haz. & Muni. Wastes 5%

Toxic Substances 5%

Safe Drinking Water 12%

Right-to-know 2%

Source: C&EN, Sept. 10, 2001, p. 28Source: C&EN, Sept. 10, 2001, p. 28Rules impact > $100 million/year since 1993Rules impact > $100 million/year since 1993

Pollution Prevention

• Containment

• Processing

• Recycling

4

Cost Drivers

• Location- Mobilization

• Containment

• Waste Disposal

Four Questions

• How can I capture it?

• How much of this will I generate?• How fast?

• After Treatment what am I going to do with it?

• What treatment system meets my discharge limits?

5

Flow International

Flow International

6

How to Pick UpContainment Pool

Courtesy- Carolina Equipment & Supply

How to Pick UpVacuum Boom

Courtesy – Carolina Equipment & Supply

7

Todd Pacific Shipyard

Baseline MetricsNSRP- Atlantic Marine

24%

24%

13%4%

24%

11%Personal

Nozzle on

Fatigue

Set-up

Delay

MajorMovement

Based on 53 hours

8

How Much Is Generated

4.314.32,500

0.5252.5940,000

2.224.4020,000

3.426.8310,000

Flow Rate per Tip

gpm

# of tips per nozzle

Nozzle Flow

gpm

Pump Pressure

Psi

Abrasive Injected WB

3.2 gallons per minute

• water only

• water+media (soluble, soft, hard)

• pressures from 15,000 PSI to 40,000 PSI.

9

Abrasive Injected WBBridge (Corrpro Study for FHWA)

• Water Consumption

0.0948005.68,5500.1222,18010.717,820

0.1536,86020.044,800

Water rate

(gal/ft2)

Water Consumed (gal)

% area deteriorated

Structure

Total ft2

Calculated Amount

• Ultrahigh pressure pump

• 4 to 6 gallons per minute

• 6 gallons/min x 60 minutes/hour x 16 hours

• = 5760 gallons in a working day

10

Rain Event• If a dock is 600 feet long and 100 feet wide

• collect the first inch of rain.

• 600 ft x 100 ft x 1 foot = 60,000 cubic feet

• 60,000 cubic feet/foot x/ 12 inch/foot = 5000 cubic feet per inch of rainfall

• 7.48 gallons per cubic foot.

• 37,400 gallons per inch of rainfall

How much do I have to clean the water?System Design

• Public owned Treatment Facility

• Discharge to Surface (sprinkler- vegetation

• Stormwater Retention Pond

• Back to Natural Body of Water

• Recirculation

11

Design RequirementsTodd Pacific Shipyard System

• 30 gpm semi-automated

• Solids: 693 ppm

• Oil & Grease: 31 ppm

• Remove Cu, Zn, Pb to– Cu 8.0 ppm– Zn 10.0 ppm– Pb 4.0 ppm

What to Use for Large Volumes

• Holding Tank – agitate, sump pump

• TREATMENT TANK – chemical to precipitate out dissolved metals

• Clarifier/Flocculation Tank- Chemical to drop out solids– Solids- Dewatering- Filter Press– Liquid- to POTW or filter (further treatment)

• Recycle- Depends on Pump

12

What to Use for Small Volumes

• Filter Bags, Baffle Tanks , Bag Filters; cone bottom tank

• Settling Tanks

• Filter for fines material

• Filter before pump

• Recycle- Depends on Pump

Boca Rotan- courtesy Nozl Tech

13

Flow International

Courtesy- Carolina Equipment

14

Pratt & Whitney

Pratt & Whitney

15

Surface Area- Comal Plant

• Interior Structural Steel 363,700 ft2

• Exterior Structural Steel 21,250 ft2

• Interior Masonry 28,600 ft2

• Exterior Masonry 5,400 ft2

WJTA proceedings, August, 2001

Ambient Air Monitoring

05

10152025303540

1 3 5 7 9 11 13 15

ug/cubic meter

Average 2.7

Non-detect except

One sample

16

Blaster Personal Breathing Zone

0

20

40

60

80

100

120

1 3 5 7 9 11 13 15 17 19 21

Jetter Air

Detection Limit 20 ug/m3

Action Limit 30 ug/m3

Average 14 ug/m3

Interior Steel

17

Waste Streams

Water Jetting Abrasive Blast

• Clarified Water Abrasive + Paint

• Hazardous Sludge

• Materials Related to Paint Same

Paint Waste Materialscommon to WJ and Abrasive Blasting

• Waste Paint Thinner 4,000 pounds

• Paint Cans and other Solids Associated with Paint 40,000 pounds

18

Analysis of Decant Water TCLP Metals

Results Reporting Limit

Regulatory Limit

Component mg/L mg/L mg/L Arsenic < 0.10 < 0.10 <5.0 Barium <1.0 <1.0 <100 Cadmium <0.10 <0.10 <1.0 Chromium <0.20 <0.20 <5.0 Lead <0.20 <0.20 <5.0 Selenium <0.10 <0.10 <1.0 Silver <0.10 <0.10 <5.0 Mercury <0.01 <0.01 <0.2

Waste Water Stream

• Clarified Water- 400,000 gallons-

• Cost to send to POTW - $1,126

• Hazardous Sludge- 10,000 gallons

• Estimated cost to dispose- $2.00/gal.

• $20,000

19

Comparable Dry Blast Waste

• Assume 8 pounds/ sq. foot usage

• (36 kg/ sq. meter)

• 3,280,000 pounds (1640 tons)

• Cost to dispose

• Non-Hazardous $106,600 ($ 65/ton)

• Hazardous $820,000 ($ 0.25/lb)

Comparing Volume

• Abrasive + Paint

• 3,280,000 pounds, or 32,800 cubic feet, or

246,000 gallons

• Water-Paint Sludge

• 10,000 gallons

• Hazardous Volume Reduction is 25: 1Estimated Project Savings $500,000

20

Summary- Comal Plant

• Project Savings Estimated at $500,000

• Reduced Waste Streams

• Minimal Environmental Impact

• No Dust

• Reduced Liabilities- Worker Safety

Wirtz Dam LBP, WJ at 20,000 psi

• Est. Dry Blast Hazardous Waste 82 tons

• Water Jet Hazardous Waste 5 tons– Includes 4 tons of silt from lake and painting

residues– Water was recirculated– Cost to incinerate $10,000

• Bidding-– dry- $700,000 WJ $411,000

21

Wirtz Dam

• 55,000 sq. feet (20,000 psi)

• Water Consumption est. 15,000 gal.– 0.3 gallon/sq foot

• Leachable Lead in Recycled Water 0.306 ug/L – (non-hazardous) went to POTW at no additional cost

Wirtz Dam

• Lead in Ambient Air <0.18 ug/m3 (nondetect)

• PM-10 <0.27 ug/m3 • (0.00 to 5.82, 24 hour)

• Personal Air Monitor 7.39 ug/m3 • (0 to 19.8, 8-Hour TWA)

22

Economic Comparison $/sq foot

$5.08

UHP WJ#

0.42Other

0.783.14Disposal

$8.02

0

0

UHP WJ*

$1.63$17.15 Total

11.04Containment

0.95Labor

0.260.44Blast material

UHP WJ**Dry Abr.*

*1995 Puget Sound Study**2000 NSRP survey of shipyards (7 doing UHP WJ)# Ongoing NSRP study- Atlantic Marine

Abrasive Injected WBBridge LBP (Corrpro Study for FHWA)

• Economics

3.264.9520%200,000

3.785.3820%50,000

7.027.7920%10,000

9.3812.1820%5,000

AIWBCost/ft2

Hand Tool cost/ft2

% area deteriorated

StructureSize

23

Pollution Prevention

• Containment

• Processing

• Recycling

Thanks•• Norman MorrisNorman Morris-- Delta Pollution ControlsDelta Pollution Controls

• UHP Projects, Carolina Equipment, Nozl-Tech

• Aqua-Dyne, Flow Int., Ingersoll-Rand,

• NLB Corp., Hydrochem, HoldTight Solutions,

• A-1 Able, Freemyer, Hammelman, Nor-Vac,

• Acquablast, Universal Minerals, Corrpro

• International Paint, Ameron Protective Coatings,

• Aulson Co., Bridgecote- Feroguard


Alternatives for Control, Collection, and Treatment of Shipyard Stormwater

Barry L. Kellems1, P.E, Fabian F. Sanchez2, Lynwood P. Haumschilt3 Presented at the 11th Annual Southern States Environmental Conference


September 2001

Abstract Shipyards are facing increased regulation of stormwater discharges through the National Pollutant Discharge Elimination System (NPDES) permitting process. While traditional Best Management Practices (BMPs) can significantly reduce the contaminantion of stormwater, BMPs alone will not be sufficient to comply with impending regulatory limits. The development of low-cost but effective stormwater control, collection, and treatment alternatives is necessary to minimize environmental compliance costs at U.S. shipyards and strengthen the public image of shipyards as stewards of the environment. This paper presents an assessment of alternatives for managing shipyard stormwater and preliminary results for an innovative technology currently undergoing testing.

1Senior Associate, Hart Crowser, Inc., 1910 Fairview Avenue East, Seattle, Washington 98102. 2Engineer, Hart Crowser, Inc. 3Consultant, LPH Consulting, 17546 Caminito Balata, San Diego, California 92128.

i


Introduction The first lines of defense for keeping pollutants out of receiving waters are source control and BMPs. It is always more cost-effective to implement source control and BMPs to prevent pollution rather than collect and treat stormwater to remove pollutants after the fact. Alternatives to direct surface water discharge of shipyard stormwater include infiltration, diversion to the municipal sewer, and treatment prior to surface water discharge. Each of these alternatives has advantages and disadvantages. In the past the standard approach for treating shipyard stormwater was by using physical-chemical methods. Recently, pilot-scale testing of organic-based filtration has proven to be a more economical treatment alternative. Full-scale testing of an organic-based filtration process is ongoing at the NASSCO shipyard in San Diego.

Characterization of Shipyard Stormwater Shipyard stormwater can be characterized as containing relatively high concentrations of metals, intermediate concentrations of solids, and low concentrations of Oil and Grease. Typical stormwater influent characteristics and discharge requirements for shipyards located in the Puget Sound region of Washington State and a shipbuilding facility in San Diego, California, are presented in Table 1. The Puget Sound influent concentrations are the average for six representative shipyards. Effluent requirements from Water Quality Standards for Surface Waters of The State of Washington (Chapter 173-201A WAC) are based on chronic toxicity. The San Diego shipyard influent concentrations are the average for drainage SW-3 at the NASSCO shipyard. Effluent requirements were calculated using the influent concentrations and toxicity discharge requirements for surface water discharge in CA RWQCB San Diego Region Order 97-36. The Oil and Grease limitation is based on a 30-day average. Typically, copper and zinc are the controlling parameters for managing shipyard stormwater. Table 1. Shipyard Stormwater Influent Characteristics and Discharge Requirements

Puget Sound Shipyard San Diego Shipyard Parameter Influent Effluent Influent Effluent

Copper in ug/L 220 3.1 340 37 Lead in ug/L 59 8.1 90 NR Zinc in ug/L 860 81 1,400 300 TSS in mg/L 40 NR 26 NR Oil and Grease in mg/L 4 NR 8 25 NR = Not explicitly regulated

Control, Collection, and Treatment Technologies

Approaches

Current technologies available for managing shipyard stormwater discharges in the U.S. have either been expensive or have not proven to be effective in reducing metals concentrations to acceptable regulatory limits. Puget Sound shipyards have established BMPs, which entail the

1


application of operational improvements and source control technologies to prevent stormwater runoff from contacting blasting grit, paint chips, oils, and other potentially contaminating material. Examples of stormwater BMPs include containment of spent grit, routine sweeping of paved areas, scheduled cleaning of sumps and drain lines, and proper storage and handling of hazardous materials (PPRC 1997). Other control technologies such as stormwater infiltration, discharge to sanitary sewer, and treatment prior to surface water discharge are site-specific and must be evaluated on a case-by-case basis prior to being implemented.

Stormwater Treatment Technologies A screening of potentially applicable technologies for treatment of stormwater discharges is presented in Table 2. These technologies were identified and screened based on potential effectiveness and technical feasibility. A cost-effective and implementable technology to control shipyard stormwater discharges is needed as the application of current treatment options (e.g., chemical precipitation and sedimentation) are impractical due to the large volumes of stormwater as well as the relatively low but variable dissolved metal concentrations in stormwater. The results of the screening survey indicated that organic-based enhanced filtration would be a viable alternative to remove metals from shipyard stormwater. Pilot Testing of Enhanced Filtration In 1997, Hart Crowser was hired by a group of shipyards in the Puget Sound region to conduct a bench-scale treatability study of enhanced filtration of stormwater. During this study, stormwater from two active shipyards was tested with three organic-based filtration media produced from leaf compost, peat, and other humic substances. The three filter media tested included: CSF Humic Filter Media, Multisorb 100, and ATA aqua-Fix. These media were selected based on their effectiveness in removing constituents of concern (COCs) in shipyard stormwater (e.g., copper, zinc, lead, and total suspended solids) and their feasibility to be implemented on a full-scale enhanced filtration testing project. Media that cannot be implemented because of lack of commercial availability or technical constraints at a typical shipyard were eliminated. A summary of the bench-scale test criteria and results for the CSF media is presented in Table 3. A treatability test was performed in multiple columns containing the selected filtration media to assess their performance during actual simulated shipyard hydraulic conditions. A layout of the test apparatus is shown on Figure 1. A short-term test using actual shipyard stormwater and a coarse media (screen size 0.11 to 0.06 inch) was performed to determine removal efficiencies and attainable discharge concentrations of the stormwater COCs. In a similar fashion, a long-term test designed to measure removal efficiencies of the dissolved metals was also performed using synthetic stormwater without solids to minimize plugging, and a finer media (screen size 0.055 to 0.023 inch). The findings of the bench-scale study revealed that the media were able to remove up to 97 and 94 percent of the dissolved copper and zinc, respectively, but that actual performance would be strongly dependent on solids loading. Based on these results, an economic cost analysis demonstrated that enhanced filtration was a cost-effective alternative for treatment

2


Table 2. Identification and Screening of Potentially Applicable Technologies (Hart Crowser 1997) Technology Description Effectiveness Technical Feasibility Screening Results Catch Basin Inserts Provide inlet protection using

commercially available fabric or insert type

Low: Does not capture dissolved pollutants or fine particulates

Medium: Has excessive operational requirements

Eliminated

Swirl Regulators and Concentrators

Catch basins or treatment units with inside structure designed to improve solids and oil removal and retention


Medium: Requires purchase of new catch basin and/or treatment system for concentrated solids

Eliminated

Detention Pond Lowers runoff velocities and allows settling of particulate pollutants


Low: Depends on land availability. Typical shipyard has low land availability

Eliminated

Biotreatment Bioswales or grass filter strips lower runoff velocity and acts as a filter to trap particulate pollutants

Medium: Limited effectiveness for dissolved pollutants

Low: Depends on land availability. Typical shipyard has low land availability

Eliminated

Sand Filtration Filter stormwater through sand filter, trapping particulate pollutants

Medium: Limited effectiveness for dissolved pollutants

Medium: Requires redesign of storm sewer lines and purchase of filtration unit

Retained for detailed analysis as baseline treatment method

Enhanced Filtration Filter stormwater through enhanced filtration media, trapping particulate pollutants. Dissolved metal removal may be possible

Uncertain: Performance data limited

Medium: Requires redesign of storm sewer lines and purchase of filtration unit

Retained for bench-scale testing followed by detailed analysis

Chemical Precipitation and Sedimentation

Design system to optimize reduction in pollutant concentrations. System may include ultrafiltration or ion exchange unit for dissolved metal removal

High: System designed to achieve optimal removal of pollutants

Medium: Requires purchase of storage tanks and treatment system

Retained for detailed analysis as baseline treatment method

3


Table 3. Summary of 1997 Bench-Scale Test Criteria and Results (Hart Crowser 2000) Unrestricted Flow Controlled Flow Removal Rate in Percent

Test Media Sieve

Size Screen Size in

Inches Flow Rate in

gpm/SF Flow Rate in

gpm/CF Average Flow

Rate in gpm/SF Average Flow

Rate in gpm/CF Copper Lead Zinc TSS Short-Term High Loading* #7 to #13 0.11 to 0.06 17 9 3.3 1.7 50 28 83 44 Short-Term Low Loading* #7 to #13 0.11 to 0.06 13 7 2.4 1.2 49 23 85 38 Long-Term 500 EBV** #14 to #30 0.055 to 0.023 14 14 2 2 97 82 94 NM Long-Term 900 EBV** #14 to #30 0.055 to 0.023 14 14 2 2 97 95 71 NM

* Short-term results based on treatment of Marco Shipyard (Seattle) stormwater, average of three effluent samples. ** Long-term results based on treatment of synthetic stormwater containing no suspended solid. Grab samples collected following treatment of 500 and 900 empty bed volumes (EBV).

NM = Not Measured

4


Figure 1. Test Column Schematic

of shipyard stormwater. As an illustration, the cost-effectiveness of copper removal is shown on Figure 2. Based on the Clean Water Act, the most cost-effective option would be located at the “Knee” of the curve, in this case end of pipe enhanced filtration. Upon completing the pilot testing, the main data gap from this study involved the long-term performance of the system under dynamic hydraulic and chemical loadings. The demonstration project currently underway at the NASSCO shipyard will address this data gap and document the performance of enhanced filtration in a full-scale, long-term shipyard application. Full-Scale Testing of Enhanced Filtration With the sponsorship of the National Steel Research Program (NSRP), full-scale testing of enhanced filtration is currently ongoing at the NASSCO shipyard in San Diego. This facility is the largest new construction shipyard on the West Coast. In partnership with NASSCO, Hart Crowser was responsible for evaluation and selection of the process options for testing, and final design of the filtration test units. Stormwater Management, Inc. (Portland, Oregon) also assisted in the project by providing equipment and installation support. The NASSCO demonstration project will complete the testing cycle of enhanced filtration and provide a comparative performance analysis of three filtration media options in a shipyard setting, as well as cost data for the industry.

5


Figure 2. Cost-Effectiveness of Copper Removal The project consists of the installation of a stormwater filtration system that treats 95 percent of the runoff from approximately 10 acres of the shipyard. System design and construction were completed in 2000 and 2001, respectively. Stormwater from drainage areas SW-3 is split using a flow splitter manhole and treated through a filtration system consisting of three different treatment trains. A flow schematic of the filtration system is shown on Figure 3. The filtration system will be an off-line facility located at the downstream end of the existing SW-3 outfall. The treatment trains consist of concrete vaults containing cartridge filters filled with various grain sizes of leaf compost (CSF) filtration media. A schematic of the patented stormwater management filter cartridge unit is presented on Figure 4. Treated effluent from the treatment vaults will pass through a simple sampling vault and then into an effluent pump station manhole, where stormwater will be pumped back to the existing outfall for discharge to San Diego Bay. To assess the effectiveness of various treatment configurations, three separate parallel treatment trains were installed. Overall, the goal of the filtration system was to test three grain size distributions of compost media for the removal of solids and metals from stormwater runoff. The operational phase of the project will be performed during storm events and will involve continuous monitoring of the filtration media for both hydraulic performance and chemical removal capacity. Initial testing has just begun, and data are still being analyzed.

6


Figure 3. Filtration System Schematic

Figure 4. Self-Cleaning Filter Cartridge

7


A comparative analysis of the stormwater monitoring data collected during testing of the three alternative treatment trains will be conducted. Based on this analysis, a preferred treatment scheme will be selected or design modifications to the existing schemes will be made. Also, the feasibility and practicability of full-scale stormwater filtration at the NASSCO shipyard will be assessed. Although full-scale testing of organic-based enhanced filtration is still underway, the effectiveness and technical feasibility of this technology in controlling shipyard stormwater discharges is promising based on the results of the bench-scale treatability study. Summary and Conclusions Because BMPs alone have not been successful in reducing concentration of COCs in shipyard stormwater to regulatory limits, a cost-effective technology to control and manage shipyard runoff is needed. Among the feasible alternatives, filtration is of interest because filters are effective during intermittent flows, and because they can be readily implemented in below-ground, gravity-flow configurations, thus minimizing the space requirement posed by building a large chemical treatment plant. In addition, the higher metal removal capacity of an organic-based filtration media produced from leaf compost have made this technology attractive to the shipyard industry. Testing performed to date has been limited to lab-scale only. Even though this technology appears cost-effective and technically feasible, actual performance and costs of enhanced filtration have not yet been established for shipyards and these will impact the actual feasibility of this treatment alternative. For that purpose, a full-scale demonstration project to provide actual cost and performance guidelines for the industry is currently ongoing at the NASSCO shipyard in San Diego. Only after the completion of this project can definite assessment of the full-scale applicability of this technology to treat shipyard stormwater be performed.

8


References Hart Crowser 1997. Shipyard AKART Analysis for Treatment of Storm Water, Final Report prepared for Maritime Environmental Coalition, May 7, 1997. Hart Crowser 2000. Demonstration of Enhanced Filtration for Treatment of Shipyard Stormwater San Diego, California. Design Report prepared for National Shipbuilding Research Program, July 2000. Pacific Northwest Pollution Prevention Resource Center (PPRC) 1997. Pollution Prevention at Shipyards, Seattle, Washington, September 1997.

9

1


Managing Shipyard Stormwater DischargesAlternatives for Control, Collection, and Treatment of Shipyard Stormwater

Barry KellemsHart Crowser, Inc. Delivering smarter solutions


Increased Regulation

• Increasingly Stringent Discharge Limitations under NPDES

• Copper and Zinc Typically Control

• Toxicity Standards Becoming More Prevalent

2

Puget Sound Shipyard San Diego Shipyard Param eter Influent(1) Effluent

(2) Influent(3) Effluent (4)

Copper 220 ug/L 3.1 ug/L 340 ug/L 37 ug/L

Lead 59 ug/L 8.1 ug/L 90 ug/L NR Zinc 860 ug/L 81 ug/L 1,400 ug/L 300 ug/L TSS 40 m g/L NR 26 m g/L NR Oil and Grease 4 m g/L NR 8 m g/L 25 m g/L

(1) Influent concentrations are the average for six representative shipyards located in the Puget Sound region of W ashington State. (2) Effluent requirem ents from “W ater Quality Standards For Surface W aters Of The State Of W ashington (Chapter 173-201A W AC) and are based on chronic toxicity. (3) Influent concentrations are the average for drainage SW -3 at the NASSCO shipyard in San Diego, California. (4) Effluent requirem ents calculated using the influent concentrations (3) and toxicity discharge requirem ents in CA RW QCB San Diego Region Order 97-36. Oil and Grease lim itation based on a 30-day average. NR = Not explicitly regulated.

Shipyard Stormwater Influent Characteristics AndDischarge Requirements


Current Technologies Limited

• Current Technology - Limited Effectiveness or Expensive

• Source Control and/or BMPs Typically Cannot Reach Limits

• A Cost-Effective Technology is Needed to Control Shipyard Stormwater.

3


Control Technologies

• Source Control

- Planning, material substitution

• Best Management Practices

- Segregation, sweeping, maintenance

• Stormwater Infiltration or Sewer Discharge

• Stormwater Treatment Prior to Surface Water Discharge


Stormwater Treatment Alternatives• Evaluation Conducted for Puget Sound

Shipyards in 1997

• Screening of Technologies Based on Effectiveness and Technical Feasibility Indicated that Enhanced Filtration (Organic-Based) Would be Viable

• Screening of Filtration Media Indicated that CSF Humic (Leaf Compost) Filter Media and Others Warranted Testing

5


Treatability Test of Filter Media

• Column Testing to Assess Performance of Various Filter Media

• Two Real Stormwaters and One Synthetic Stormwater Tested

• Average Coarse Media Zinc Removal of 80%

• Average Coarse Media Copper Removal of 50%

• Fine Media Removals up to 100%

6

Total Copper, Total Zinc, And TSS Results for Fine Compost Column Test

Run Avg. TSS Conc. (mg / L) Avg. Total Cu Conc. (mg / L) Avg Total Zn Conc. (mg / L)Influent Effluent Removal Influent Effluent Removal Influent Effluent Removal

1 25.5 1.0 96% 0.555 0.095 83% 2.800 0.190 93%2 15.5 1.5 90% 0.335 0.060 82% 1.600 0.076 95%3 19.0 0.0 100% 0.135 0.026 81% 0.715 0.043 94%4 52.5 3.6 93% 0.605 0.096 84% 4.250 0.125 97%5 14.5 0.0 100% 0.345 0.068 80% 1.800 0.099 95%6 17.5 1.0 94% 0.340 0.068 80% 1.650 0.097 94%7 4.0 0.0 100% 0.075 0.025 67% 0.180 0.029 84%8 23.5 1.0 96% 0.575 0.074 87% 3.000 0.092 97%9 25.0 1.5 94% 0.420 0.061 86% 1.600 0.054 97%10 21.5 1.0 95% 0.390 0.057 86% 1.600 0.050 97%

Average 96% 82% 94%

7


Cost Analysis

• Economic Reasonability Test

• Enhanced Filtration Most Cost Effective

• Data Gap = Full-Scale Performance Under Dynamic Conditions

8


Demonstration ofEnhanced Filtration• NSRP Sponsored Project at NASSCO Shipyard

• Test Three Grain-Size Distributions of Compost Media During Multiple Storms

• Treat 95% of the Runoff from Approximately10 Acres

• Design Completed 2000

• Construction Completed 2001

• First Test (Artificial Storm) September 2001

12

Self-Cleaning Filter Cartridge

14


Conclusions• A Cost-Effective Technology is Needed

to Control Shipyard Stormwater.

• Organic-Based Filtration is a Viable Alternative Based on Lab-Scale Tests

• Full-Scale Demonstration is On-Going at NASSCO Shipyard.

Laboratory Analysis of Stormwater A Practical Guide

By: Jason Mennino Environmental Engineer

Northrop Grumman Ship Systems Ingalls Operations

Shipyards throughout the United States are required to have an National Pollution Discharge Elimination System (NPDES) permit. These permits dictate the allowable constituents of all direct discharges to a receiving stream. Unfortunately, the constituent analyses shipyards must live by are taken for granted and are mysteries to most managers. This paper is a practical guide from sample collection to laboratory integrity. Sample Collection Sample collection is one of the most controversial issues. It is true that a bad sample will, in turn, give bad results. Therefore, it is absolutely essential to acquire “good” samples. Before taking a sample, one must determine what the sample will be analyzed for. The containers are especially important because some analytes require glass rather than plastic. Because some analytes are light sensitive, samples must be placed in an amber container rather than a clear one. Depending upon the analysis, an aqueous sample can be preserved with an acid or acid mix or not preserved at all. For example, metals samples should be preserved with Nitric acid while Phenols and Oil & Grease (O&G) should be preserved with Sulfuric acid. When considering the preservation issue, be certain that the sample volume is adequate for the analyses required. For example, a semi-volatile analysis requires a liter whereas a volatile analysis requires two 40mL vials. Consult the laboratory before conducting any sampling to be sure the proper sample volumes are collected. The permit requirements will dictate the sampling method, whether it is a grab sample at some interval or a 24-hour composite. Grab samples are just that. A sample is collected at a specific location and at a specific time. A composite-sampling scheme usually employs an auto-sampler, which will “grab” a sample at a given interval but will place the samples in distinct sample bottles. When the 24-hours or total time is up, the auto-sampler is collected and returned to the lab for compositing. Usually, an equal volume from each of the bottles is poured into a consolidation container and then passed on to the appropriate lab for analysis. Throughout the sampling procedures, there are two main principles that must be adhered to at all times. The first is refrigeration. All samples must be kept cool. For example, a cooler with an ice pack. The other issue is hold time. Certain parameters must be analyzed within a certain period of time or the analysis will be invalid. Hydrogen ion concentration (pH), for example, must be analyzed immediately whereas O&G can sit on the shelf for 28 days or less. Be sure to understand all hold time issues prior to sampling. Once the samples are collected, they need to be transported to the laboratory. Before shipment, be sure to include enough ice packs to ensure the samples will be kept cool until they reach the lab. Major freight carriers will usually ship samples as long as they

pose no major health risk. The most important thing to remember about sample shipment is a document called the Chain Of Custody (COC). This is a legally binding document, a “mini-contract”, that holds the last person who signed it responsible for the samples. This document must be signed before samples are shipped. This document travels with the samples to the lab where it is then signed by the lab. Now that the samples have been shipped, the waiting game begins. Unfortunately, not many people know what happens to their samples once they reach the lab. The rest of this paper will describe the process from when the samples arrive at the lab to the QA/QC protocols. Samples arrive at the lab Once the samples reach the lab, a responsible lab person signs the COC. The samples are then taken to a Sample Login area where the cooler is unpacked, samples are inspected, samples are matched against the COC for quantity & identification, and then distributed to the appropriate labs for analysis. It may seem like a menial task, but it is quite labor intensive. The sampling dates are determined from the COC and the samples are screened for hold times. If any hold times are breached, the customer is contacted and asked to resample because any analysis for that parameter would be invalid. After the samples pass through the Sample Login area, they are distributed to the various labs: Wet Chemistry, Metals, Semi-volatiles (SVOC), Volatiles (VOC), and Microbiology (Micro) Lab. Table 1. Labs and the analyses performed

Wet Chemistry Metals

O&G Nitrate Dissolved COD Nitrite Totals - TCLP TSS Phosphate Mercury BOD Sulfate pH Sulfite Conductivity Chloride Chlorine Cyanide TKN

Volatiles (VOC) Semi-volatiles (SVOC)

TCE PAH - Polyaromatic Hydrocarbons Vinyl Chloride TPH - Total Petroleum Hydocarbons Other chlorinated solvents Herbicides Brominated compounds Pesticides BTEX compounds Acid-Base Neutrals (ABNs) - N/A MTBE DRO – Diesel Range Organics GRO - Gas Range Organics

2

Obviously each of the labs has its own area, but the Volatiles lab is completely separate from the rest of the labs including its own air handling system. This is necessary because the Volatiles lab can become contaminated by the Semi-volatiles lab, resulting in “false positives” for chlorinated solvents such as Methylene Chloride. Analytical Technologies Each of the labs above utilizes various analytical technologies for constituent determination. The analysis technologies are listed below:

• Chromatography - Ion Chromatography (IC) - Gas Chromatography (GC)

• Infrared Spectroscopy (IR) • Inductively Coupled Plasma (ICP) • Atomic Absorption (AA)

Chromatography Chromatography is the science of separating mixtures of compounds, elements, or ions. The separation of these mixtures into components occurs because the components have different partition ratios between the mobile phase (gas or liquid) and the stationary phase (column). Therefore, they exhibit different rates of travel through the column. In other words, compounds will dissociate (break-up) at different times depending upon the compound, for example NO3. This anion will travel through the column at a certain rate while another anion, SO4, will take longer to travel the same distance. This will be explained in more detail later in the paper. There are two types of chromatography, liquid and gas. Liquid chromatography uses a liquid as the mobile phase to carry the components through the column. This type of chromatography is carried out around room temperature and conducted, for the most, in the Wet Chemistry lab. Gas chromatography uses a gas as the mobile phase, but because of the heated injectors and ovens, the components must be thermally stable and have a reasonable volatility. Gas chromatography requires significant sample heating (~300°C), therefore the components must be thermally resilient. GC work is primarily performed in the VOC and SVOC labs. Ion Chromatography Ion Chromatography (IC) is a method of liquid chromatography that is conducted in the Wet Chemistry lab. An IC is a physical piece of equipment that can be considered the workhorse for anion analysis. The inner workings of an IC are unimportant but the understanding that an IC uses liquid chromatography is very important because of detection limits, which will be discussed later. Another liquid chromatographic method is HPLC or High Performance Liquid Chromatography. HPLC can be used for just about anything but is very expensive and very labor intensive. This method is primarily used for research purposes because of its wide array of capabilities but, because of its cost and labor requirements, renders itself impractical in an environmental lab. Table 2 illustrates typical components that can be analyzed using an IC.

3

Table 2. IC analytes

Acetate Nitrate Azide Nitrite Bromate Oxalate Bromide Perchlorate Chlorate Phosphate Chloride Sulfate Cr(VI) Sulfite Fluoride Sulfonic Acids Iodide

The following figure1 really illustrates the liquid chromatography concept. As can be seen, the various components are time dependent (x-axis). Gas Chromatography Gas chromatography, as explained above, is performed in both SVOC and VOC labs. However, the methods are vastly different. The SVOC performs an extraction using Methylene Chloride and then takes that extract and introduces it into the GC (Gas Chromatograph, the physical equipment). The VOC lab utilizes a Purge & Trap

4

1 Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th Edition; 1992; 658.

technique. The sample is decanted into a tube where gas (usually H2) is “bubbled” through the aqueous sample. The gas is routed to a Trap where it is heated and then introduced into the GC for analysis. Chromatography Detection The GC can use a multitude of detectors depending upon the analytes of interest. There are primarily four types of detectors employed in environmental labs: Thermal Conductivity Detector (TCD), Flame Ionization Detector (FID), Electron Capture Detector (ECD), and Photoionization Detector (PID). Thermal Conductivity Detector A TCD responds to any compounds whose thermal conductivity differs from the carrier gas, usually Helium. As the carrier gas move through the TCD, the thermal conductivity is constant. When an analyte passes through the TCD, the conductivity drops. This conductivity drop shows up as a peak and the height of the peak indicates the degree of conductivity drop. Flame Ionization Detector An FID uses an H2 and air flame which ionizes organic compounds into electrons and positive ions. The electron stream is then sent through a polarization circuit, which sees a current. The current is proportional to the amount of compound in the flame. The current shows up as a peak in the GC output. Electron Capture Detector An ECD employs a radioactive isotope of nickel, Ni63. The Ni63 is an β-emitter that emits a constant stream of electrons. There are two electrodes that have a standing (constant) current between them. The current decreases (electron flow interrupted) when an organic species passes through the detector. The current decrease is measured and shows up as a peak on the GC output. This detector can be likened to a flashlight and the human eye. With the flashlight shining at the wall, there is a light intensity, which causes a round shape. If you pass your hand between the flashlight and the wall the beam is interrupted with the shadow of your hand. If there were some sort of light detector on the wall, it would record a drop in light intensity. Photoionization Detector A PID uses a high-energy ultraviolet lamp for ionization. The electrons stream from ionization through a polarization circuit, which sees current. The current is proportional to the amount of component. The current shows up as a peak in the GC output. This is the same as the FID but uses an ultraviolet lamp instead of a flame. Infrared Spectroscopy (IR) Infrared Spectroscopy (IR) is the absorption of radiation in the infrared region by a typical organic molecule. The IR radiation absorption results in an excited molecule. The excitation results in state transitions (vibrational/rotational). State transitions are the vibrational, rotational, and bending modes a molecule undergoes when excited. The vibrational mode is the molecule’s bonds stretching like a rubber band. Rotational mode is fairly self-explanatory where the molecule rotates in one direction. The bending

5

modes consist of wagging, rocking, scissoring, and twisting. The following figure2 illustrates the aforementioned state transitions. IR is typically used for organics such as Total Petroleum Hydrocarbons (TPH). There are a plethora of commercial instruments used in the Wet Chemistry lab. Once the analysis is performed and an IR spectra produced, the IR spectra is compared to an IR spectra library of known compounds to determine the constituents. The following figure3 is a typical IR spectrum. The compound analyzed in this spectrum is a thin polystyrene film.

2 Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th Edition; 1992; 255 3 Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th Edition; 1992; 253

6

Inductively Coupled Plasma (ICP) is used primarily for metals analysis. An aqueous sample is pumped from the sample container to a nebulizer where it is vaporized. An inert carrier gas, usually Ar, brings the sample to the torch. The torch “burns” (~8000 K) the vapor, thus ionizing it. After the ions are formed, they are in an excited state, and emit light at different frequencies or wavelengths. The light emissions are detected by Atomic Emission Spectroscopy. The following figure4 illustrates the architecture within the actual equipment. Atomic Absorption Spectroscopy (AAS) Atomic absorption spectroscopy is the measurement of specific light wavelengths gaseous neutral atoms emit after absorbing radiant energy. When a neutral atom is irradiated with light energy it will absorb some of that energy and become excited. Just like ICP, AAS is an elemental analysis where the molecule is reduced to an elemental state and then vaporized. The vapor is sprayed into a source radiation beam of a specific wavelength. That light is absorbed by the element and the difference in light

7

4 Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th Edition; 1992; 236.

intensity between the absorbed light and the raw source beam determines the concentration of the constituent. The sample is atomized in one of two ways, either through flame atomization or flameless atomization. Flame atomization is much like that of ICP. The sample is “sprayed” through a nebulizer into a flame. The flame atomizes the sample and the atoms travel through a light source (radiation beam) where the absorbance is measured. Flameless atomization is vastly different, in that, the sample passes through a carbon tube where it is electrically heated. An example of a flameless atomizer would be a graphite furnace. The benefit of flameless atomization is that solid samples can be run without preliminary extractive work. Also, the detection limits are much better with flameless atomization because the residence time (the time a substance resides within an analytical environment) in the atomizer is much greater resulting in better sample atomization. One of the drawbacks of flame atomization is oxide production. Because the sample is “burned” in a flame, oxides are produced which can cause inter-element interferences. The AA is used for Mercury analyses because of the minute detection limits. As mentioned above, the atomizer of choice is the graphite furnace. The following figure illustrates the architecture of a typical AA instrument.

Courtesy of the University of Akron Chemistry Department

Quality Assurance/Quality Control Quality assurance as defined by the Standard Methods for the Examination of Water and Wastewater, 20th edition is the “definitive program for laboratory operation that specifies the measures required to produce defensible data of known precision and accuracy.” The definitive program is outlined in a QA manual that all labs must have. The manual contains written procedures, work instructions, and records. Quality control ensures that the methods are carried out correctly and should contain the following:

8

1. Initial demonstration of capability 2. Ongoing demonstration of capability 3. Detection limit determination 4. Method blanks 5. Method blank spikes 6. Matrix spikes 7. Matrix spike duplicates 8. Duplicate samples 9. Internal standards 10. Surrogate standards (organic analysis) 11. Calibrations

The first three points prove the lab can perform the analyses with good repeatability and meet the minimum detection limit. The rest of the points (4-11) are relative to a specific sample run and should be requested with the final report. These points provide good insight as to how meaningful the results are (i.e. quality controls). There are other criteria but these are the key elements. If one of these is missing or cannot be produced upon demand, the laboratory’s reliability and integrity are in serious question. The QA/QC plan will contain the aforementioned elements but will also include lab SOPs (Standard Operating Procedures). The SOPs are the actual methods the lab personnel perform to conduct the analysis. In other words, anyone with a reasonable chemistry background should be able to pick up an SOP and perform an analysis. SOPs are usually kept in the lab where the analysis is performed. However, at larger labs, there may be a centralized database or library that houses them.

9

References

1. Standards Methods for the Examination of Water and Wastewater, 20th Edition;

1998 2. Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th

Edition; 1992 3. Dionex Corp. - www.dionex.com 4. Varian, Inc. - www.varianinc.com 5. Lachat Instruments - www.lachatinstruments.com 6. West Coast Analytical Services - www.wcas.com 7. Merck Eurolab - www.chromatography.co.uk 8. ChemSW, Inc. – http://chemsw.com 9. Surface Analytical - www.icp-oes.com 10. Materials Evaluation & Engineering, Inc. - www.mee-inc.com

http://www.dionex.com/

http://www.varianinc.com/

http://www.lachatinstruments.com/

http://www.wcas.com/

http://www.chromatography.co.uk/

http://chemsw.com/

http://www.icp-oes.com/

http://www.mee-inc.com/

1

09/27/01 Southern States Environmental Conference 2001 Shipyard Track

1

Laboratory Analysis of Stormwater

Jason MenninoEnvironmental Engineer

Northrop Grumman Ship SystemsIngalls Operations


2

Why should you care??

• Proof of compliance– MSGP– Individual permit

• Background studies for new permits• Integrity/Accuracy

– Laboratory– Results

2


3

Common Stormwater Parameters• Oil & Grease• COD• TSS• BOD• pH• VOCs• Metals

– Zn– Cu

• Conductivity• Inorganics

– NO3

– NO2

– Cl2

– CN– SO4

– SO3

– Chloride


4

Sampling• Containers

– glass v. plastic– amber v. clear

• Hold time issues• Preserved v. Unpreserved• Refrigeration• Sample size/quantity• Grab v. composite

– auto samplers

3


5

Transport to Lab

• Chain of Custody– Must be signed

• Refrigeration– Cooler w/ice packs

• Courier• Other shipping means


6

Samples arrive at laboratory

• Sign COC– Release legal custody

• Sample login– Unpack cooler– Sample inspection– Match samples to COC

• # of samples• sample ID’s

– Parameter delineation• hold time issues

• Sample Distribution– Wet Chem lab– Metals lab– Semi-Volatiles

(SVOCs) lab– Volatiles (VOC) lab– Microbiology lab

• Usually N/A for stormwater

4


7

Wet Chem Lab• Parameters

– Oil & Grease– COD– TSS– BOD– pH– Conductivity– Chlorine– TKN– CN

• Inorganics– NO3

– NO2

– PO4 - ortho– SO4

– SO3

– SO2

– Chloride


8

Metals Lab

• Dissolved• Totals

– TCLP• Mercury (Hg)

5


9

Semi-volatiles (SVOC) Lab

• PAHs - Polyaromatic Hydrocarbons• TPH - Total Petroleum Hydrocarbons• Herbicides• Pesticides• Acid/Base Neutral (ABN) - N/A


10

Volatiles (VOC) Lab• TCE• Vinyl chloride• Other chlorinated solvents• Brominated compounds• BTEX compounds• MTBE• DRO - Diesel Range Organics• GRO - Gas Range Organics

6


11

Analysis Technologies

• Chromatography– Ion Chromatography (IC)– Gas Chromatography (GC)

• Infrared Spectroscopy (IR)• Inductively Coupled Plasma (ICP)• Atomic Absorption (AA)• Other


12

Chromatography

• Science of separating mixtures of compounds, elements, or ions

• The separation of these mixtures into components occurs because components have different partition ratios between the mobile phase (gas or liquid) & the stationary phase (column), and therefore exhibit different rates of travel through the column

7


13

Chromatography

• 2 types– Liquid Chromatography (IC or HPLC)

• Uses a liquid as the mobile phase to carry the components of the mixture through the column

• Carried out near room temperature– Gas Chromatography (VOC & SVOC)

• Uses a gas as the mobile phase, but because of the heated injectors and ovens in GC, components must be thermally stable and have reasonable volatility (boiling points below 400-500oC)


14

Ion Chromatography (IC)

• Liquid Chromatography• Widely utilized in most labs• Anion analysis• Wet Chem lab

8


15

IC Analytes

• Acetate• Azide• Bromate• Bromide• Chlorate• Chloride• Cr(VI)• Fluoride• Iodide

• Nitrate• Nitrite• Oxalate• Perchlorate• Phosphate• Sulfate• Sulfite• Sulfonic Acids

16

9

17


18

Gas Chromatography

• Used in SVOC lab– Methylene Chloride extraction– Used to use Freon

• Used in VOC lab– No extraction– Purge & trap

10

19


20

GC Detectors• Thermal Conductivity Detector (TCD)

– Responds to any compound whose thermal conductivity differs from carrier gas (He, has high TC)

– TC constant until analyte present, then drops– Wheatstone Bridge sees the TC difference as voltage

which determines concentration

• Flame Ionization Detector (FID)– Utilizes flame (H2 + air) which ionizes organic

compounds into e- & positive ions.– e- stream sent through polarization circuit, sees current,

which is proportional to amount of compound in flame.

11


21

GC Detectors cont’d• Electron Capture Detector (ECD)

– Standing current between electrodes– b-emitter Ni63 emits constant stream of e-

– Current decreases with presence of organic species that capture e- - measured by Electrometer

– Detection & determination of chlorinated insecticides

• Photoionization Detector (PID)– Uses high energy UV lamp for ionization, detection

same as FID– Must have right lamp to ionize compounds– Very finicky and tricky - an Artform !!


22

Thermal Conductivity Detector

12

23


24

Photoionization Detector

13


25

Electron Capture Detector


26

*Table 2. Comparison of Saturn System MDLs with Current and (Proposed) MCLs2,3Compound MCL(ppb) Saturn System MDLBenzene 5.0 0.03

1,2-Dibromo-3-chloropropane (0.2) 0.01

1,2-Dibromoethane (0.5) 0.01

Carbon tetrachloride 5.0 0.02

1,4-Dichlorobenzene 75.0 0.02

1,1-Dichloroethene 7.0 0.02

1,2-Dichloroethane 5.0 0.01

Tetrachloroethene (5.0) 0.01

Trichloroethene 5.0 0.01

Vinyl chloride 2.0 0.03

*Taken from Varian GC/MS application note Number 8.

14


27

Infrared Spectroscopy (IR)• Absorption of radiation in the infrared region by a

typical organic molecule results in the excitation of vibrational, rotational, and bending modes

• State transitions• Vibrational

– stretching• Rotational• Bending

– Wagging– Rocking– Scissoring– Twisting

28

15


29

IR cont’d

• Typically used for organics– e.g. TPH

• Spectra library developed– compare spectra to determine constituents


30

Inductively Coupled Plasma (ICP)

• Primarily performed on metals• Sample introduced - nebulized (vaporized)• Carried into torch by inert carrier gas (Ar)• Aerosol/vapor “burned” at ~8000 K• Ions formed & excited, emit light at different frequencies -

detected by atomic emission spectroscopy• Lower interelement interferences• Very expensive• Requires intense operator knowledge and time

16

32

17

33


34

Atomic Absorption Spectroscopy (AAS)• Atomic absorption spectrometry - absorption of

radiant energy by neutral atoms in the gaseous state

• Elemental analysis– Reduction to elemental state– Vaporization– “Sprayed” into source radiation beam

• Sample atomization - nebulizer• Flame atomization

– Nebulizer controls flow– sprayed into flame for spectra– oxides produced as artefact (interferences)

18


35

AAS cont’d• Flameless atomization

– Samples placed in carbon tube & electrically heated• Graphite furnace• Residence time greater – improved DLs and sensitivity• Can also run solid samples

• Interferences arise when sample atoms collide with other species causing energy exchange, broadens spectral lines

• Spectra analysis– Temperature dependent– +/- 2% accuracy

• For metals only – other elements form oxides too rapidly• Quantitative analysis only

36Courtesy of University of Akron Chemistry Department

19


38

Quality Assurance/Quality Control (QA/QC)

• Laboratory SOPs– Standard Operating

Procedures (methodology)

• Matrix Spikes– duplicates

• Blanks– duplicates– laboratory– field

• % Recovery• Chain of Custody

20


39

References• Standards Methods for the Examination of Water and

Wastewater, 20th Edition; 1998• Skoog, Douglas A. & Leary, James J.; Principles of

Instrumental Analysis, 4th Edition; 1992• Dionex Corp. - www.dionex.com• Varian, Inc. - www.varianinc.com• Lachat Instruments - www.lachatinstruments.com• West Coast Analytical Svcs. - www.wcas.com• Merck Eurolab - www.chromatography.co.uk• ChemSW, Inc. - chemsw.com• Surface Analytical - www.icp-oes.com• Materials Evaluation & Engineering, Inc. - www.mee-

inc.com

Speaker Biographies and Presentation Abstracts

LEGAL REQUIREMENTS FOR SHIPYARD STORM WATER DISCHARGES

By: Joseph Green, Senior Associate and John L. Wittenborn, Partner

Collier Shannon Scott, PLLC 3050 K Street NW, Suite 400

Washington, DC 20007 (202) 342-8514

[email protected] Session: Shipyard Stormwater Management Tuesday, September 25, 2001 3:00 - 4:30 PM

Under its plenary authority pursuant to the Federal Water Pollution Control Act ("FWPCA"), as amended, the Environmental Protection Agency ("EPA") has developed a comprehensive program to regulate the discharge of pollutants into waters of the United States. The authority to regulate is the same regardless of whether the pollutants being discharged are in process wastewater or storm water. However, the regulatory programs differ in significant ways. Under its storm water management regulations, EPA proposed a tiered approach to regulating storm water discharges. To date, EPA has implemented that approach through promulgation of several permit programs -- a baseline general permit, an industry multisector general permit and two rounds of municipal permits. These permit programs generally include a Best Management Practices ("BMP")-based approach to control the introduction of pollutants into storm water. EPA is also looking to control storm water discharges through a watershed approach under its Total Daily Maximum Load ("TMDL") program as well as through facility-specific ("NPDES") permits tailored to the operations and pollutants of individual facilities. This presentation will describe the scope and evolution of the Storm Water Permitting Program, its legal underpinnings and where it is likely to go from here. Along the way, the presentation will define key terms from the statute and regulations, explain EPA's Clean Water Act authority to enforce the Storm Water Discharge Program requirements and outline the regulatory compliance options available to facilities including shipyards. The presentation will also describe the relationship between the storm water regulatory program for shipyards and the proposed Metal Products and Machinery categorical effluent limitations guidelines ("ELG") rule for drydocks and land-based ship construction and repair activities.

Biographical Sketch John, a partner at Collier Shannon Scott, PLLC, since 1985, heads the firm's environmental and health and safety practice group. His practice includes counselling on regulatory compliance and permitting matters under all of the environmental programs, litigation and enforcement defense, cost recovery actions, environmental due diligence and lobbying. His practice and the Collier Shannon Scott, PLLC, environmental practice under his leadership are national in scope involving representation before Congress, the U.S. Environmental Protection Agency, state regulatory agencies and federal and

state courts. His clients include steel manufacturing companies, shipbuilders, leather tanneries, refineries, paper and forest products and other manufacturing companies and national associations representing these industries. He is a distinguished graduate of the United States Air Force Academy (1971) and holds a J.D. Degree from Indiana University (cum laude, 1974) and an L.L.M. Degree in environmental law with highest honors from George Washington University in 1980. Formerly, Mr. Wittenborn served as Chief of the Environmental Litigation Division for the U.S. Air Force and Assistant Chief of the Environmental Enforcement Section, United States Department of Justice. Joe, is a senior associate at Collier Shannon Scott, PLLC. He joined the firm’s environmental and health and safety practice group in 1996. His practice includes counseling on regulatory compliance and permitting matters under all of the environmental programs, including water, chemicals, air, waste and right-to-know. His practice and the Collier Shannon Scott, PLLC, environmental practice is national in scope involving representation before Congress, the U.S. EPA, state regulatory agencies and federal and state courts. The clients he works with include steel manufacturing companies, shipbuilders, leather tanneries, refineries and other manufacturing companies and national trade associations representing these industries. He holds a J.D. degree from Harvard Law Scholl (cum laude, 1996), graduated with high distinction from the University of Virginia (B.A., 1993), and is currently pursuing his masters in law from the George Washington University Law School (candidate for L.L.M. in International Environmental Law, 2001)

Halvax 1

CLEAN WATER ACT CITIZEN SUITESA CASE STUDY

By:Sandor (Shaun) Halvax

Manager of Material Business ManagementSouthwest Marine, Inc.

P.O. Box 13308San Diego, CA 92170-3308

(619) [email protected]

Session: Shipyard Stormwater ManagementTuesday, September 25 2001, 3:00 - 4:30 PM

The Federal Clean Water Act generally allows for the filing of a lawsuit by any party who claims to havebeen adversely affected by the discharge of another. While the successful filing of a citizen suite requiresmany facts to be proved, opinions on what is legally required to sustain a successful suite may surprise you.

This is a case study of a shipyard that believed it was implementing best management practices and stormwater controls, such that it was effectively controlling the operations (and discharges) at it’s facility.

This presentation is intended to provide an overview of the Federal Clean Water Act requirements forsustaining/defending an allegation of violation of the Act, and will compare and contrast some specificjudicial findings for each of these requirements.

Biographical Sketch

Shaun is currently employed with Southwest Marine, Inc. and is charged with developing and implementingenvironmental programs for three shipyards in California. He has been employed by Southwest Marinefor the past five years. Prior to Southwest Marine, Shaun was employed by Continental Maritime of SanDiego for 15 years where he managed all aspects of facility and environmental planning.

Shaun is a California Registered Environmental Assessor, and he also holds a General EngineeringContractors License with the State of California.

Shaun’s education includes a Bachelor of Science in Production and Operations Management, a Bachelorof Arts in legal studies, and a Professional Certificate in Hazardous Materials Management.

Killeen 1

SHIPYARD REGULATORY REQUIREMENTS FOR STORMWATER DISCHARGES

By:Pat Killeen, R.E.M.Corporate Director

Environmental ComplianceFriede/Goldman/Halter

PO Box 3029Gulfport, MS 39505


Session: Shipyard Stormwater ManagementTuesday, September 25, 2001 3:00 - 4:30 PM

Polluted storm water runoff is a leading cause of impairment to the nearly 40 percent of the surveyed U.S.water bodies which do not meet water quality standards set forth by the United States EnvironmentalProtection Agency. Over land or via storm sewer systems, polluted runoff generally is discharged directlyinto local water bodies. When left uncontrolled, this water pollution can result in a negative effect upon fish,wildlife, and aquatic life habitats; a loss in aesthetic value in addition to the possibility of threatening publichealth.

Storm water discharges from shipyard and ship-repair facilities is typically generated by runoff from thefacility’s impermeable surfaces such as parking lots, production ways, and other water-resistant areas (e.g.,buildings, units under construction) during rainfall and/or snow events. Much of this discharge often containspollutants in quantities that could adversely affect the water quality of the effluent-receiving stream. Withthat, most storm water discharges are considered point sources and therefore require coverage by aNational Pollutant Discharge Elimination System (NPDES) permit.

In addition to the regulatory requirements, the ‘Shipyard Regulatory Requirements for StormwaterDischarges’ presentation will demonstrate shipyard stormwater permitting processes and procedures,incorporate methodologies to control storm water discharges through the use of best management practicesand contain a mixture of significant web-links that will allow attendees to research stormwater regulationsas correlated to individual facilities and locations after returning from the conference.

Biographical Sketch

Patrick is an accredited Registered Environmental Manager (REM) via the National Registry ofEnvironmental Professionals. In addition to his duties as Corporate Director of Environmental Compliance

Killeen 2

for Friede Goldman Halter, Inc., he is currently a member the USEPA’s Sustainable IndustriesProgram/Technical Advisory Panel regarding the ‘Environmental Management Systems Template for theShipbuilding & Ship Repair Industry’. He also is the current Chairman of the Board for the ‘ShipyardAssociation for Environmental Responsibility’ (SAFER) which is principally a Gulf of Mexico wideshipbuilding/ship repair trade organization that addresses regional industry environmental issues and theimpact/outcome of these regulations upon the industry. Patrick also is, and has been a member of theNational Shipbuilding Research Program (NSRP) environmental technical advisory panel, SP-1, since1996.

Kwan 1

AGENCY ENFORCEMENT OF SHIPYARD STORMWATER DISCHARGES

By:Kenneth Kwan

US Environmental Protection Agency, Region 461 Forsyth Street, SW

Atlanta, GA 30303-8960(404) 562-9752

[email protected]

Session: Shipyard Stormwater ManagementWednesday, September 26, 2001 10:00 - 11:30 AM

This presentation is intended to provide an overview of EPA’s storm water enforcement program. It willexamine the role between the States and EPA in storm water enforcement. The presentation will includeinformation about how efforts are prioritized under EPA’s Storm Water Enforcement Strategy, how EPAdetermines permit compliance, and the various enforcement responses to violations. Finally, Region 4’sstorm water inspection program will be addressed. It will focus on the types of problems and deficienciescited during inspections at shipyard facilities.

Biographical Sketch

Kenneth is the Storm water enforcement expert for EPA Region 4. In this capacity, he oversees the stormwater enforcement for eight southeast states. Kenneth also has over 15 years of experience in theenforcement of industrial and municipal wastewater treatment facilities. Kenneth received a Bachelor ofCivil Engineer degree from Georgia Institute of Technology. He is a Registered Professional Engineer inthe State of Georgia.

Holt & Maher 1

STORMWATER PERMITTING OF SHIPYARD STORMWATER DISCHARGES

By:

Wayne S. HoltDirector Safety/Environmental

Atlantic Marine, Inc./ Atlantic Dry Dock Corp8500 Heckscher DriveJacksonville, FL 32226


AndJim Maher

Supervisor of Industrial Wastewater for the Northeast DistrictFlorida Department of Environmental Protection

7825 Baymeadows Way Suite B200Jacksonville, FL 32256



The permitting of stormwater discharges from shipyards is a very complex process. Becauseshipyards are necessarily located directly adjacent to a navigable body of water, there are severalunique issues that must be addressed in association with the stormwater permit. In many cases,stormwater management opportunities utilized by land-locked facilities can not be practicallyimplemented in a shipyard. In addition to the constraints of location, the sheer magnitude ofshipbuilding and ship repair operations also present several unique issues that must be addressedin the stormwater permit. Many of the activities and operations conducted in a shipyard are bynecessity conducted outdoors, and in many cases while the vessel is still in the water. Workactivities in a shipyard also tend to be cyclical and transient. Consequently, the potential forstormwater exposure is quite high. The application of conventional stormwater management “bestmanagement practices” (BMPs) can not always be effectively implemented given the size of thefacility, the volume of stormwater, and its proximity to the receiving water body.

Equally complex and problematical is the development of a regulatory based stormwater dischargepermit. Stormwater discharge regulations are designed to prevent the significant deterioration ofthe quality of a body of water that receives stormwater run-off from a potentially pollutant source.In many cases, the regulations are of a “one size fits all” variety and are very narrowly defined with

Holt & Maher 2

regard to allowable pollutant concentrations, monitoring and analysis protocols, and requiredmanagement activities. This significantly constrains the permit writer and leaves him with littleflexibility to address facility specific issues.

There is however, a resolution to overcoming the constraints encountered by both the facility andthe regulatory agency, in developing a permit that meets all the applicable regulatory requirementsand is also achievable for the facility. That is “Partnering”, partnering in a collaborative effort,sharing information and ideas toward a mutually beneficial end. Notwithstanding the obviousregulatory implications, the discharge of stormwater from any facility that may be contaminated withthe by-products of its operations, has the potential for having a detrimental impact on theenvironment. A responsible corporate entity should conduct its operations not merely to attainregulatory compliance, but to have the least environmental impact possible. Logically, a facilityneeds to conform it’s operations and stormwater management BMPs to meet and/or exceed wherepossible, the regulatory requirements. In order to do so, the facility must have intimate knowledgeof the permitting process and where permitting flexibility exists to fit its facility specific operations.Likewise, until a permit writer has intimate knowledge of the facility lay-out, operations andprocesses, exposure potentials and existing stormwater management BMPs, he is not equipped toadequately address facility specific constraints in managing stormwater discharges. Most regulatoryagencies possess engineering staffs with a wealth of expertise and experience in permitting for manytypes of facilities. This experience and expertise is indispensable in assisting the facility in orientingit approach toward stormwater management.

A collaborative, systematic and comprehensive investigation of all aspects of a facility that has thepotential for impacting stormwater is essential prior to the commencing to draft the permit.Additionally, the sharing of concerns and ideas gives both the facility and the regulatory agency afeel for the others perspective, and in many cases results in the impetuous of an innovative solution.Moreover, by working through all of the contentious issues up front in a collaborative partnership,by the time the first draft of the permit is written, both sides are already essentially in agreementwith the contents, thus avoiding the litigation that is often quite common in after-the-fact permitnegotiations. Finally, there is the benefit of the relationships that develop through this process, asregulators and facility personnel recognize each others perspective and gain respect for thecommon end that they are both trying to reach.

Biographical Sketch

Wayne is the Environmental and Safety Director for Atlantic Marine, Inc. and Atlantic Dry DockCorporation located in Jacksonville, Florida. He has been with the Atlantic Companies for 8 years,and oversees the administration of all environmental, industrial hygiene, and general safety relatedissues. Wayne received a Bachelors of Science degree in Architectural Engineering from FloridaA & M University and a Masters of Science degree in Environmental Engineering from La Salle

Holt & Maher 3

University. He has also received accreditation as a Registered Environmental Manager (REM #8288) and a Certified Environmental Auditor (CEA # 7894) through the National Registry ofEnvironmental Professionals. Wayne is a member of the National Association of EnvironmentalProfessionals, the American Society of Safety Engineers, and the American Society of NavalEngineers. Additionally, he is a certified OPA-90 Qualified Individual, and certified both as aMarine Fire Fighter and a Competent Person by the National Fire Protection Association. Waynealso holds an Asbestos Air Monitoring Lab certification through the American Industrial HygieneAssociation. In addition to performing his duties at Atlantic, Wayne is the Chairman of the FirstCoast Manufacturers Association Environmental, Health, and Safety Committee and has servedas a Project Manager for a variety of environmental projects being performed through the NationalShipbuilding Research Program.

Jim is the Supervisor of the Industrial Wastewater Section for the Northeast District office of theFlorida Department of Environmental Protection (FDEP). He has been with FDEP for 12 yearsafter serving in the US Navy. Jim received a Bachelor of Science degree in Chemical Engineeringfrom Lehigh University and a Masters of Business Administration from the University of NorthFlorida. At FDEP he is responsible for administration of NPDES program for surface waterdischarges from paper mills, power plants, chemical plants, dairies, and various other industries.Additional duties include Domestic Wastewater NPDES permitting; funding development forwastewater facility upgrades; development of TMDLs and is the agency representative for effortsto fully restore the St. Johns River. He served as chairman of a St. Johns River Task Force andis an agency representative on the Governor’s Harmful Algae Bloom Task Force and assists in thedevelopment of NPDES inspector training. Jim is a Registered Professional Engineer in the Stateof Florida. He also does software programming for a Financial Valuation company.

Austin 1

SHIPYARD STORMWATER POLLUTANT SOURCES AND LOADING

By:Dana M. Austin

PresidentDana M. Austin Environmental Consulting, Inc.PMB 233, 450 State Road 13 North, Suite 106

Jacksonville, FL 32259(904) 287-1034

[email protected]


Various shipyard operations and processes can be the source of pollutants found in shipyard stormwaterdischarges. It is important to identify the pollutant types, their potential sources and estimate the loadingfrom these sources, to determine where Best Management Practices to control the discharges can beapplied.

This paper examines several common shipyard operations and processes to determine the types ofpollutants generated and estimate their loading in stormwater. A structured format to evaluate the sources,pathways and discharges points for shipyard stormwater pollutants is developed. This evaluation processcan be applied by the shipyard environmental manager for their specific facility, location, operations andprocesses. Based upon this evaluation, Best Management Practices can then be developed andimplemented to specifically target those sources and pathways that are the greatest contributors tostormwater pollution.

Biographical Sketch

DANA M. AUSTIN ENVIRONMENTAL CONSULTING, INC.PRINCIPAL 1995 - Present

Provide superior industrial environmental affairs management consulting services to a national client base.

SOUTHWEST MARINE, INCORPORATED

CORPORATE MANAGER OF ENVIRONMENTAL AFFAIRS 1991 - 1995INDUSTRIAL ENVIRONMENTAL MANAGER 1989 - 1991

Provided leadership in planning, directing and overseeing corporate and divisional industrial operations compliance withenvironmental protection regulations. Directly accountable for 4 major company divisions; advise management personnelin regulatory interpretation, implementation and liability issues; supervise all technical operations.

Austin 2

CHEMICAL SAFETY ASSOCIATES, INCORPORATED

SENIOR ASSOCIATE 1987 - 1989ASSOCIATE 1985 - 1987

Provided environmental and chemical safety consulting and training services while developing business within a nationalclient base. Conducted site audits, occupational monitoring and accident investigations; analyze clients' project operations,identified problems, and assessed compliance/safety needs and formulated recommendations. Organized, scheduled andinstructed client personnel in customized safety, regulatory and emergency response programs.

ECOSYSTEMS MANAGEMENT ASSOCIATES, INCORPORATED

CHEMICAL PROJECTS MANAGER 1984 - 1987CHEMIST / RESEARCHER / DIVER 1982 - 1984

Headed project execution for this environmental consulting enterprise focused on near shore ocean processes includingmarine geology, chemistry and physical oceanography. Directed field personnel in collecting samples; enforced samplingprotocol and diving safety practices. As Laboratory Manager, analyzed samples, maintained safety and quality control;controlled budget; trained and supervised staff performance.

PROFESSIONAL ACTIVITIES

Board of Directors ! Past Chairman & Member, Environmental Health/Risk Assessment Committee:INDUSTRIAL ENVIRONMENTAL ASSOCIATION

Past Chairman & Member, Environmental Committee: PORT OF SAN DIEGO SHIP REPAIR ASSOCIATIONMember, Environmental Committee: SHIPBUILDERS COUNCIL OF AMERICA

Member, Facilities and Environmental Effects Panel: SOCIETY OF NAVAL ARCHITECTS AND MARINE ENGINEERSBoard of Directors _ Chairman, Environmental Committee: SAN DIEGO PORT TENANTS ASSOCIATION

EDUCATION

Certification in Air Quality Management, 1994: University of California at San Diego ExtensionCertification in Hazardous Materials Management, 1988: University of California at San Diego Extension

Master of Science in Marine Biology, 1980: Scripps Institute of Oceanography, University of California at San DiegoBachelor of Science in Biochemistry, 1973: University of California at Irvine

Frenzel 1

HYDRO BLASTING AND WATERJETTING IN THE MARINE CONSTRUCTIONINDUSTRY AS RELATED TO WASTE MINIMIZATION AND POLLUTION

PREVENTION

By:Lydia M. Frenzel, Ph.D.

Executive DirectorAdvisory Council

PO Box 2139San Marcos, TX 78667

[email protected]

www.advisorycouncil.orgwww.waterjetting.org

Session: Shipyard Stormwater ManagementThursday, September 27, 2001 10:30 AM - 12:00 N

Hydro Blasting and Water-Jetting in the Marine Construction Industry “Renewing America with RenewableResources”. Everyone talks about clean air and clean water. The marine industry and coatings removalis an industry driven by tradition and the natural response is that change will be more expensive and difficultto do. Since 1985, waterjetting has moved from a curiosity in coatings removal to become a reality. Noone feels comfortable with change.

Forces which drive companies away from traditional dry abrasive blast cleaning are safety and health,economics, environmental, and performance issues. The convergence of the thought processes by theshipyard or contractor, the owner, and the coatings manufacturer have to combine with the driving forcesto make evolution possible.

We will examine how this continual improvement evolution came about and what the change means to themarine construction industry in terms of waste minimization and pollution prevention. We will look at thevolumes of water produced by watterjetting compared to storm water run-off.

Biographical Sketch

50 publications, 45 presentations at meetingsExecutive Director of the Advisory CouncilPh.D. 1971- University Of Texas at AustinRecipient of the 1996 Technical Achievement Award for Steel Structures Painting Council,

Frenzel 2

Member of the Board of Directors for the Water Jet Technology Association, 1995-2001, Vice-President- 1999- to present

Chair of the SSPC- NACE Wet Abrasive Blast and Water Jetting Standards Task Groups NACE representative to ISO Waterjet Working GroupPast District Governor, Rotary International District 5190, 1997-98.Known as the “Water Witch of the West!”

Kellems 1

ALTERNATIVES FOR CONTROL, COLLECTION, AND TREATMENT OF SHIPYARDSTORMWATER

By:Barry L. Kellems, P.E.

Senior AssociateHart Crowser, Inc.

1910 Fairview Avenue EastSeattle, Washington [email protected]


Shipyards are facing increased regulation of stormwater discharges through the National PollutantDischarge Elimination System (NPDES) permitting process. While traditional Best Management Practices(BMPs) can significantly reduce the contaminantion of stormwater, BMPs alone will not be sufficient tocomply with impending regulatory limits. The development of low-cost but effective stormwater control,collection, and treatment alternatives is necessary to minimize environmental compliance costs at U.S.shipyards and strengthen the public image of shipyards as stewards of the environment.

The first lines of defense for keeping pollutants out of receiving waters are source control and BMPs. It isalways more cost-effective to implement source control and BMPs to prevent pollution rather than collectand treat stormwater to remove pollutants after the fact. Alternatives to direct surface water discharge ofshipyard stormwater include infiltration, diversion to the municipal sewer, and treatment prior to surfacewater discharge. Each of these alternatives has advantages and disadvantages. In the past the standardapproach for treating shipyard stormwater was by using physical-chemical methods. Recently, pilot-scaletesting of organic-based filtration has proven to be a more economical treatment alternative. Full-scaletesting of an organic-based filtration process is ongoing at the NASSCO shipyard in San Diego.The presentation describes and summarizes the advantages and disadvantages of the various alternativesfor managing stormwater at shipyards. Treatment performance and cost data show the relative effectivenessand implementability of infiltration, diversion to the municipal sewer, and physical-chemical treatment versusorganic-based filtration prior to surface water discharge.

Biographical Sketch

Barry has 16 years of environmental engineering experience and is a registered Civil Engineer in Alaska,California, and Washington. He received a Bachelor of Science degree in Civil Engineering from OregonState University and a Master of Science degree in Environmental Engineering from Cornell University.

Mennino 1

LABORATORY ANALYSIS OF STORMWATER

By:Jason Mennino

Environmental EngineerIngalls Shipbuilding

PO Box 149, M/S 8021-01Pascagoula, MS 39568-0149



Because all shipyards are required to have an NPDES permit, some sort of monitoring programmust be put in place to ensure that the permitted stormwater limits are not exceeded. Therefore,samples must be collected as dictated by the permit, and sent to a lab for analysis. What happensto these stormwater samples once they reach the lab can be a bit of a mystery. This presentationwill clarify the process from sample collection to analysis.

It will include some sampling requirements and techniques. The technologies, from GC/MS to asimple pH meter, that labs use to determine constituent concentrations will be discussed. QA/QC,which is composed of many constituents, is essential to obtain reliable results and is oftenmisunderstood by those outside of the laboratory environment. Finally, an explanation for theramifications and the potential effects certain pollutants can have on the environment.

Biographical Sketch

Jason graduated from the University of Dayton with a degree in Environmental Engineering. Priorto working at Ingalls Shipbuilding, he was a Research Scientist/Project Manager for YSI Inc. inYellow Springs, Ohio. As a part of their Environmental Products Group, he assisted in the designand development of a chlorophyll probe and multi-probe assembly. Before working at YSI Inc.,he was a chemist for a small laboratory in New Hampshire. Along with the daily laboratoryanalyses, he performed a variety of tasks including sanitary sewer, landfill and stormwater sampling

“Managing Shipyard Stormwater Discharges” - InfoHouseinfohouse.p2ric.org/ref/24/23288.pdf ·...

Documents

Transcript of “Managing Shipyard Stormwater Discharges” - InfoHouseinfohouse.p2ric.org/ref/24/23288.pdf ·...