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KEEPING YOUR FACILITY IN COMPLIANCE
Environmental Regulatory Compliance for DPW Operations
Regulatory Programs at the DPW
Today’s Topics…
NJ Air Quality Program
Underground Storage Tanks – Common P bl d th i S l tiProblems and their Solutions
Stormwater Permitting – NJDEP’s Municipal and Industrial Stormwater Programs
Federal Spill Prevention Control and Countermeasure Rule – Recent Changes & Proposals
NJ’s Discharge Prevention Program
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New Jersey Air Quality Permitting Program
Air Quality at DPWs
Greenhouse Gas Emissions Emergency GeneratorsGasoline Dispensing Facilities
Stage II Vapor RecoveryPortable Equipment General Permit
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FiveFive--year Assessment states:year Assessment states:Without Without strongstrong mitigation action: mitigation action:
Temperature change in next 100 yrsTemperature change in next 100 yrsGreater than change in last 10,000 yrsGreater than change in last 10,000 yrs
GHG and Climate Change
g , yg , y
Precipitation cycles will change Precipitation cycles will change change uneven across the globe and over change uneven across the globe and over
timetimeswift, severeswift, severesea levels rise sea levels rise -- GlobalGlobalserious challenge to human and ecosystem serious challenge to human and ecosystem
adaptation adaptation
Global temperature changes have always been a fact of life, but
since 1860 the average temperature has been on
Since the industrial revolution, as carbon
dioxide concentrations
temperature has been on the rise.
dioxide concentrations have risen, so too have
temperatures.
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Passage of Global Warming Response ActMandates –
Executive Order 54By Governor Corzine on February 13, 2007
GHG emission reduction to 1990 levels by 2020 a 20% reduction
Reduction to 80% below 2006 levels by 20502050
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Greenhouse GasesSix Major GHGs -Identified by Kyoto Protocol
Carbon dioxide (CO2)Methane (CH4)Methane (CH4)Oxides of Nitrogen (N2O) Hydrofluorocarbons
(HFCs)Sulfur hexafluoride (SF6),
andPerfluorocarbons (PFCs)( )
Global Warming Potential (GWP)
Abilities of different greenhouse gases to trap heat in the atmosphere
- heat-absorbing ability of each gas g y g- decay rate of each gas (typically over 100
years)GWP measured relative to that of CO2
Emissions (tons) converted to CO2 equivalents (CO2Eq)
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Gas 100-Year GWPCO2 1
Global Warming Potential (GWP) for Greenhouse Gases
CH4 21N2O 310
HFC-23 11,700CF4 5,700CF4 5,700SF6 23,900
Regulatory frame work:Regulatory frame work:None exists at federal levelNone exists at federal levelNone exists at state levelNone exists at state level
Emissions Calculations and Reporting
None exists at state levelNone exists at state level
No reporting requirements exist No reporting requirements exist --YETYET
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Emissions Calculations and Reporting
Voluntary Reporting Programs
California Climate Action Registry
GHG Protocol - World Resources Institute
Voluntary Reporting - Energy Information Administration (EIA) US Department ofAdministration (EIA) - US Department of Energy
GHG Emission Profile
Consider the objective: Why are we doing this???
Green and good corporate citizenship;
Join a voluntary reporting program:
Climate LeadersCli t A tiClimate Action
Registry
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GHG Emission ProfileProcess Overview
Establish a base-line yearCalculate base-line emissionsSet targets for emission
reductionIdentify emission reduction
opportunitiesEstablish an emission
reduction programMeasure the success of the
program
Air Permitting
Emergency Generators37 kW and greater must comply with record keeping requirements1 MMBTU Gross Heat Input 1 MMBTU Gross Heat Input requires permitPrior to testing emergency generators 37 KW and greater, must
Check the Air Quality Forecast
http://www.state.nj.us/dep/aqpp/
New EG General Permit GP-005
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General Permit – Portable Equipment
This General Permit is for engines with a maximum rated horsepower of up to 1400 HP and associated
t bl d ill i tportable and ancillary equipment which is operated as a dedicated group.Engine Gross Heat Input of 1.0 MMBTU/hrGenerators have been exempted from this General Permit
Gasoline Dispensing FacilitiesGDFs 2,000 gallons or greater require a General Air Permit (GP-004)
Stage II Vapor Recovery is required for GDFs that dispense a twelve month average of 10,000 gallons per month or morega o s pe o t o o e
GDF with Stage II Vapor Recovery must perform the following tests:
Annual Static Pressure Test (CARB TB 201.3)
Annual Pressure Vacuum Valve Test (CARB TP-201.1E)
Annual Air to Liquid Volume Ratio for vacuum assist systems, where applicable (CARB TP-y , pp (201.4)
Dynamic Backpressure Performance Test (CARB TP-201.5) (required every 3 yrs)
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Need more info?http://www.state.nj.us/dep/aqpp/ – Current Air Regshttp://www.state.nj.us/dep/opra/online.html - Search existing permits & ID’s
Underground Storage Tank Regulations N.J.A.C. 7:14B
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Regulated UST Owners - Be Aware
Guidance was issued by the USEPA regarding UST Inspections and State Compliance Reporting:p g
States had until August 8, 2007 to inspect all USTs for compliance, and
States must re-inspect each regulated tank every 3 years.
UST Enforcement In the News…
NJDEP Enforcement ActionPenalty Assessed - $15,000Camden County Facility – December 2007
UST Registration Certificate not available. Fill Ports not marked Sumps and spill buckets not inspected/cleaned No valid registration certificate issued by the Department. Failure to submit an accurate UST Questionnaire.
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What is an Underground Storage Tank
"Underground storage tank“Set forth in N.J.A.C. 7:14B-1.4,
Includes piping, lines, fixtures, and other related equipment, used to contain an accumulation of hazardous substances,
The volume of which, including the volume of the piping, lines, fixtures and other related equipment, is 10 percent or more beneath the surface of the groundg
What is a Hazardous Substance as per N.J.A.C.7:14B
Motor fuel;Petroleum products which are liquid atPetroleum products which are liquid at standard conditions of temperature and pressure;All substances which are liquid at standard conditions of temperature and pressure listed in Appendix A of N J A C 7 1E dN.J.A.C. 7:1E; andWaste oil.
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So What’s Regulated
USTs containing motor fuels, waste oil orUSTs containing motor fuels, waste oil or hazardous substances in any volume
Heating oil USTs in excess of 2,000 gallons, or aggregate volumes in excess of 2,000 gallons
Administrative Requirements
Registered with NJDEP – UST Facility g yQuestionnaire Must maintain a valid registration certificate Demonstrate proof of financial responsibility
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Construction Requirements
Regulated USTs must contain:
Corrosion Protection
Release Detection Monitoring (w/exceptions)
Spill Prevention (w/exceptions)
Overfill Prevention (w/exceptions)
Inspection and Testing Requirements – Leak Detection
All USTs - Monthly leak detection documentation
Pressurized Piping–
automatic line leak detectors, and
l li ti ht t t thl it i ithannual line tightness test or monthly monitoring with an approved method
Suction Piping –
line tightness test every 3 years, or
monthly monitoring with an approved method
Supply/Return Piping
monthly monitoring with an approved method, or
tightness test every 3 years and water presence for each delivery
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Piping Sumps and Sensors
No monitoring is required for European or Safe Suction Piping where:
Inspection and Testing Requirements – Leak Detection
Safe Suction Piping where:
Piping is sloped back to tank, and
One check valve is located as close as possible to the suction pump
Requires verification through as built drawingsRequires verification through as-built drawings
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LLDs
Monitors for a measured pressure drop each time dispenser is activated
Veeder Root
p– Restricts flow or alarms
Vaporless
Red Jacket
Corrosion Protection
Corrosion Protection Systems
Cathodic Protection T t d 1/3– Tested 1/3 years
Impressed Current –Tested 1/3 years and inspected every 60 days
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Spill ProtectionSpill buckets, sumps and dispenser pans
Inspected monthly for liquid, debris and to verify integrity
Spill buckets must also be inspected prior to deliveries
All Inspections must be recorded
Piping Sump
Dispenser Sump/Pan
Spill Bucket
Dispenser Sump/Pan
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Overfill Prevention
Overfill Prevention Equipment Must:Automatically shut off flow at 95% full; orRestrict flow/trigger a high level alarm at 90%Restrict flow/trigger a high level alarm at 90% full; orRestrict flow 30 minutes prior to overfilling, alert the operator with a high level alarm one minute before overfilling, or automatically shut off flow into the tank so that no fittings above the tank top are exposed to product due to overfilling
Common UST Compliance IssuesFailure to provide appropriate LDM for pipingFailure to have LLDs and test annuallyFailure to keep all sumps/spill buckets free of debris/liquids and record inspectionsIncorrect completion of USTFQp QFailure to provide Financial Resp. or COIFailure to maintain corrosion protection requirementsFailure to record leak detection reports monthlyFailure to have and post a Release Response PlanFailure to investigate all LDM alarmsOverfill audible/visual alarm not detectable from fill portsFailure to obtain air permits for gasoline USTs (where applicable)Failure to properly mark fill portsFailure to have piping test boots removed after installation
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Need Additional Info…
http://www.nj.gov/dep/srp/bust/bust.htmtm
http://www.epa.gov/swerust1/ustsystm/leakdet.htm
N.J.A.C. 7:14ANew Jersey Pollutant Discharge Elimination
System
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Stormwater Permitting History
Phase I Rules –1990; regulated stormwater discharges from certain industrial facilities and medium-large MS4s.1991 - Intermodal Surface Transportation Efficiency Act (ISTEA) – exempted certain industrial activities operated by municipalities w/ pop.<100,000 from Phase I Rules.Dec. 1999 - Phase II Rules - extended ISTEA Exemption until March 10, 2003. February 2, 2004 – NJDEP published NJPDES amendments in response to EPA’sNJPDES amendments in response to EPA s Phase II RulesMarch 2004 - MSRP
Stormwater Programs for Municipal Operations
Municipal Stormwater Regulation Program (MSRP)
All 566 municipalities, 21 Counties, Public All 566 municipalities, 21 Counties, Public Colleges and other public entities
Industrial Stormwater Permitting Program
Eleven categories of industrial activities
May include municipal wastewater treatment plants, landfills and bus transportation facilities
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The Goals of Both Programs
Identify all source material and activities that generate source materialmaterialEliminate exposure of source material from stormwater through BMPsEliminate non-stormwater ate o sto atedischarges from operations
What is Source Material
Any material or activity that can impact stormwater quality
Greased parts, batteries, treated woods, tires, all petroleum products, misc. chemicals, road waste, used tires, hydraulic parts, drums, open dumpsters (other than paper), de-icing materials, paints, millings, cold patch, leaking vehicles, derelict
/vehicles, used vehicle/equipment parts, used batteries, etc.
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Are these items stored properly?
Cover from precipitation
•Cleary label all containers
•Store all liquids on spill pallets
Separate Incompatible Materials:
•Oil based paints / batteries / compressed gases
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Typical Non-Stormwater Discharges
Discharges from floor drains and oil/water separatorsCompressor and boiler blowdownUnauthorized discharges from secondary containment structurescontainment structuresCooling tower bleed offFilter backwash waterHydrostatic testing waterWater main disinfection waterVehicle/equipment wash waters Construction dewateringPlant effluent (requires Beneficial Re use Permit)Plant effluent (requires Beneficial Re-use Permit)
Municipal Stormwater Regulation Program
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Municipal Stormwater Regulation ProgramTier A and B General Stormwater Permits
Both required adoption of a Municipal Stormwater Management Plan and Stormwater Control Ordinance by April 2006
Tier A required the completion of a Stormwater Pollution Prevention Plan by April 2005
Permit Cycle Based Upon EDPA (Typically 4/1 through 3/31)
Permit is up for renewal in 2009
Where should you be today?
Post Construction Municipal SMP and SCO be adopted and enforced
Ensuring Compliance with RSISCompleting long term O&M of BMPs on municipal propertiesEnsuring the long term O&M for BMPS on private properties is conductedMeeting new design standards for storm drain inletsEnsuring compliance with the SCO
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Where should you be today?
Implementing Local Public Education
Distribution of NJDEP Brochure to all residents and b i ANNUALLYbusinesses ANNUALLY
Conducting an ANNUAL educational event
Distributing pet waste brochure with pet licensing
100% complete with storm drain inlet labeling b A il 2009program by April 2009
Don’t forget about the long term maintenance
Where should you be today?
Implementing Improper Disposal of Waste
Enforcing Pet Waste, Litter, Improper Disposal of Waste Yard Waste Collection and Illicit ConnectionWaste, Yard Waste Collection and Illicit Connection Ordinances
Implementing Illicit Connection Elimination Program and complete initial inspections of all outfalls by April 2009
100% complete with storm drain outfall mapping p pp gprogram by April 2009
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Where should you be today?
Implementing Solids and Floatable Controls
Performing monthly street sweeping and recording waste totals & distance sweptRetrofitting storm drain inlets during road projectsAnnual inspection and cleaning of all stormwater facilitiesImplementing roadside erosion control and outfall stream scouring remediation programs
Where should you be today?
Implementing Maintenance Yard Operations BMPsMust have and maintain permanent storage structure for deicing material (April 2007) and comply with uncovered clean sand set back of 50 feetfeet
Specific requirements for fabric structuresImplementing SOPs (and regular inspections) for Fueling Operations, Vehicle Maintenance and Good HousekeepingPlanning the cessation of the discharge of vehicle wash waters by February 2009
The washing of firefighting vehicles has been added ll bl di has an allowable discharge
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Where should you be today?
Performing Annual Employee TrainingEJIF Stormwater Training Video –MEL website www.njmel.org or by DVD submitted to EJIF Members
Updating and recertifying the SPPP AnnuallyUpdating the source material inventory and BMPs annuallySubmitting Annual Report and Certification ELECTRONICALLY by May 2 of each year (Tier A)ELECTRONICALLY by May 2 of each year (Tier A)
Common Problems with ImplementationVehicle Fueling SOP – Implementation of Bulk Delivery RequirementsGeneral Good Housekeeping SOP –Regular inspections of DPW yards forRegular inspections of DPW yards for source materialIdentification of Municipal Stormwater Facilities and inspection/maintenance of these systemsProper Management of Road Waste and p gWastewaters Generated During Inlet Cleaning
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Basic Industrial Stormwater General Permit
Who is RegulatedMany Industrial Facilities depending on their SIC Code
Transportation Related Facilities (i.e. School Bus Transportation)
WASTEWATER TREATMENT FACILITIES with…
Design Flow of 1 Million Gallons per Day (MGD)
OR
Approved pretreatment d 40CFRprogram under 40CFR
Part 403 (i.e. Delegated Agency)
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Basic Industrial Stormwater General Permit – (5G2) EDPA 5/15/07
Authorizes new and existing industrial stormwater discharges to surface waters and/or groundwaters of the Stateand/or groundwaters of the State.
Goal is to eliminate exposure of source materials w/in 18 mo. of EDPA
If facility cannot eliminate exposure, must apply for Individual Permitpp y
Non Applicability Form (NAF)
All stormwater is directed to a CSO, or Stormwater discharge is authorized under existing NJPDES DSW or DGWunder existing NJPDES DSW or DGW Permit, orPermanent No Exposure – Source material and/or activities are performed within permanent structures
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Some Common Source Operations…. Fueling and Bulk Fueling OperationsChemical Storage and Delivery AreasSludge Loading and Unloading AreasSeptage Recei ing AreasSeptage Receiving AreasMaintenance Material Storage AreasService water wash down areasSolids drying padsDumpsters containing materials other than office and kitchen wasteS ff f i jStormwater runoff from construction projectsOutdoor Welding/Sandblasting Operations
Don’t Forget! – Annual Certification & Training
Required to submit an annual certification form - (“Generic Certification Form”)
Inspect site each year to see if new source material or source operations have been addedDon’t Forget Annual Employee TrainingTraining
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Spill Prevention Control and Countermeasures
USEPA 40 CFR 112
What is the EPA’s Oil Program?December 11, 1973 – Original SPCC Rule – 8 pages
“Oil Pollution Prevention Regulation” created to address oil spill provisions in the Clean Water Act of 1972
1988 – Ashland Oil Spill – 4 million gallons into Monongahela River
1991, 1993, 1994 – EPA proposes and adopts revisions to the original SPCC Rule
July 17, 2002 – Final Revised Rule – 112 pagesAddresses & clarifies revisions from 1991, 1993, 1997
December 2006 – Amendments – Streamlines rule for smaller, qualified facilities
October 1, 2007 – Proposed Amendments – Additionally streamlines rule to encourage greater compliance
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Regulates the aboveground storage of oils, petroleum and non petroleum in excess of
Spill Prevention Control and Countermeasures
p p1,320 gallons stored in containers 55 gallons and greater
Must have route to navigable waters, waters leading to navigable waters, or ability to migrate off-sitemigrate off site
SPCC Applicable Containers Include…
Aboveground Storage TanksMobile fueling tanksMobile fueling tanksWet TransformersDrumsGenerator Sub-base TanksEquipment with Oil Reservoirs (e.g. hydraulic fluid)EtEtc.
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Section 112.1 (d)(6) ― Wastewater Treatment Facility Exemption
… if a wastewater facility or part thereof is used for the purpose of storing oil, then there is no p p gexemption, and its capacity must be counted as part of the storage capacity of the facility…At permitted wastewater treatment facilities, storage capacity includes bulk storage containers, hydraulic equipment associated with the treatment process, containers used to store oil which feed an emergency generator associated with wastewater treatment…
Recent SPCC Rule Amendments
Effective February 26, 2007Streamlines Requirements for:
Qualified Facilities with an oil storage capacity of 10,000 gallons or less10,000 gallons or lessOil Filled Operational EquipmentMobile Re-Fuelers
Clarifies requirements for Motive Power Equipment
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What is a Qualified Facility?
Qualified Facilities10,000 gallons or less of aboveground petroleum storageN t bl di h f 3 i t lNo reportable discharge for 3 years prior to plan certification
Reportable DischargeA single discharge to a navigable water exceeding 1,000 gallons; orTwo discharges to navigable waters each exceeding g g g42 gallons within a 12 month period
Qualified Facility Benefits Self certify without P.E.
Streamlined integrity testing for ASTs
Streamlined security requirements
Streamlined requirements for oil filled operational equipment
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Other ChangesMobile Re-fuelers
No longer requires sized secondary containmentGeneral secondary containment requirements apply
Motive Power ContainersBulk storage container used to power vehicleExempt from the SPCC RuleTransfer to motive power containers still an applicable activity
SPCC – October 2007 Proposed Amendments
Will allow “Tier 1 Qualified” facilities to use a SPCC templateMaximum individual container of 5,000 gallons Site wide total does not exceed 10,000 gallons No reportable discharge in the past three years
Features of Tier 1 Qualified FacilityyChanges to Overfill protection
Tank sight gauge & employee observation during transfer operations acceptable Include brief overfill prevention practices description
No Corrosion Protection for buried pipingFacilities which deviate from SPCC template and use “Environmental Equivalence” measures must be certified by P.E.
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SPCC – October 2007 Proposed Amendments
EPA proposes to add a “Tier 2 Qualified Facility” & “Tier 3 Qualified Facility” Descriptions
Tier 2 5 001 d 10 000 ll f t t l il t5,001 and 10,000 gallons of total oil storage capacity Written SPCC Plan required but no PE certification
Tier 3 Greater than 10,000 gallons These facilities would be required to have a written SPCC Plan certified by a PE
Pitfalls Site plan must identify all storage containers, direction of flow, and access to navigable waterwayGeneral secondary containment requirements y qapply to fuel delivery areas
Fuel delivery area must include a pre-deployedmechanism for preventing discharge from a likely spill
Failure to provide leak detection and overfill protection mechanisms for ASTsPlan must be signed by Management and PEPlan must be signed by Management and PE (as appropriate)
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Need Additional Info…http://www.epa.gov/oilspill/spcc.htm
NJDEP Discharge Prevention ProgramN.J.A.C. 7:1E
Discharge Prevention Containment and Countermeasure Plan
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Who is Regulated?
“Major Facilities” with a combined storage capacity of at least:
20,000 gallons or more of hazardous substances
200,000 gallons or more of hazardous substances including petroleum products
What is Regulated?
All containers greater than 5 gallons containing:
Liquid petroleum and petroleum productsAll chemical substances listed in Appendix A –All chemical substances listed in Appendix A –
liquid, powders and gasesSolid metals > 100 micrometers excluded
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Once You’re In…
• Key provisions include:
– Discharge Prevention, Containment and C t (DPCC) l d Di hCountermeasure (DPCC) plan, and a Discharge Cleanup and Removal (DCR) plan
– Testing and inspection of above-ground storage tanks – Assuring adequate secondary containment – Developing standard operating procedures – Maintaining security– Training employees
K i i d d– Keeping required records
Important Things to Consider
Must use the total volume of substanceMost Chemicals Listed in Appendix A
do not have a de minimus quantity
Equivalent measure for solids and gasesTotal volume, in gallons, of the drum,
tote or other container holding the hazardous substanceThe calculated volume, in gallons, of
the space the hazardous substance the space the hazardous substance occupies if not transported or stored in containers
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Typical Chemicals to ConsiderPolymers – percentages of Acrylamide and Adipic Acid
Acids
Sodium Hypochlorite
Sodium Hydroxide
Potassium Permanganate
Sulfur Dioxide
ChlorineC o e
Calcium Hypochlorite
And many others…
More Information:http://www.nj.gov/dep/rpp/brp/dp/index.htm
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