Managing Shipyard Stormwater Discharges

Transcription

Proceedings of the
2001 Shipyard Environmental Issues
th
Track of the 11 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
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
Director of Environmental Compliance
Friede Goldman Halter
Dana M. Austin
President
Jacksonville, Florida
June Carpenter, PhD
Technology Transfer Specialist
Mississippi Technical Advisory Program
Mississippi State University
Mississippi State, Mississippi
Teresa Amato, Esq.
Program Manager
US EPA Sustainable Industries Partnership Program
Washington, D.C.
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
1
Joseph 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) 3428849 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
2
Recently, 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.
3
4
Some states may require shipyards and other facilities to obtain individual storm water permits.
Forty-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.
2.
3.
4.
5.
6.
7.
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;
Preventative maintenance of storm water management devices and facility equipment;
Spill prevention and response procedures;
Annual (at least) facility inspections;
Employee training (annual for responsible employees);
Recordkeeping and internal reporting procedures;
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].
Managing Shipyard
Stormwater Discharges
Legal Requirements For Shipyard Storm
Water Discharges
Joseph J. Green, Esq.
Washington, D.C.
(202) 342-8849
[email protected]
Southern States Environmental Conference
September 25, 2001
1
History of Storm Water Regulation
! Clean Water Act prohibits the discharge of any
pollutant 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)
September 25, 2001
2
•1
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)
September 25, 2001
3
EPA Permitting Strategy
November 16, 1990 Phase I Storm Water Rule:
!
Tier I: Baseline Permitting
General permits have been developed to cover initially the majority of
storm water discharges associated with industrial activity -- including
shipyards.
!
Tier II: Watershed Permitting
Facilities 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 Permitting
Specific industry categories will be targeted for individual or industry-specific
general permits.
!
Tier IV: Facility-specific Permitting
A variety of factors will be used to target specific facilities for individual
permits.
September 25, 2001
4
•2
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?
September 25, 2001
5
September 25, 2001
6
•3
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.
September 25, 2001
7
"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)
September 25, 2001
8
•4
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.
September 25, 2001
9
"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
September 25, 2001
10
•5
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
September 25, 2001
11
Storm Water Permitting Options
1.
Individual Permit
2.
Group Permit
3.
General Permit
September 25, 2001
12
•6
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
!
September 25, 2001
13
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)
September 25, 2001
14
•7
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
September 25, 2001
15
Shipyards General Permit
Like 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
September 25, 2001
16
•8
Storm Water Pollution Prevention
Plan (SWPPP)
Two major objectives:
!
1.
2.
Identify potential sources of pollution; and
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
September 25, 2001
17
Storm Water Pollution Prevention
Plan (SWPPP) (cont.)
!
Major components of SWPPP:
1.
2.
3.
4.
5.
6.
Storm Water Pollution Prevention Team: who will
develop and implement SWPPP
Identify potential pollutant sources (activities and
materials)
Inventory of exposed materials
Direction of flows
List of significant spills and leaks during last 3
years
Existing discharge sampling data
September 25, 2001
18
•9
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.
3.
4.
5.
6.
7.
8.
9.
!
Preventive maintenance of storm water management devices and facility equipment
Spill prevention and response procedures
Inspections -- monthly, records
Employee training (annual for responsible employees)
Recordkeeping and internal reporting procedures
Non-storm water discharges: identify and certify
Sediment and erosion control
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
September 25, 2001
19
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 landbased shipyard facilities
-storm water is not regulated under the
proposal
-covered by MSGP
September 25, 2001
20
•10
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
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.
The Clean Water Act (CWA)
Southern States Environmental Conference 2001 Shipyard Track
Presented by:
Shaun Halvax, SWM
A CASE STUDY ON A JUDICIAL
VIEW OF THE CLEAN WATER ACT
AND CITIZEN SUITES
Introduction
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.
Clean Water Act Implementation
1
Specific Issues Presented
• The Notice Letter
• Standing
• Alleged Wrongful Conduct
• Decision/Judgment
• Relief Granted
The Notice Letter
• Adequacy
• Alleged deficiencies in
– Development of NPDES/Storm Water Plans
– Implementation of plans
• Housekeeping
2
Adequacy of Notice Letter
• Notice letter must be sufficiently specific
as to what is wrong
– Notice letter recites permit requirements
Alleged Deficiencies
• The alleged wrongful conduct must be
ongoing a the time of the filing of the
notice
3
• Standing
• Relief Granted
Article lll Standing
• Requirements
– Injury in fact
– Fairly traceable
– Redressable by favorable decision
4
Injury in fact
• Satisfied when plaintiffs
– “…aver that they use the affected area…”
– “…for whom the aesthetic and recreational values…
will be lessoned by the challenged activity"
Fairly traceable to the
challenged activity
• Scientific certainty not required
• Discharge of pollutant that causes or
contributes to the injuries alleged
5
Redressable
• Favorable decision would redress the
injury alleged
– Plaintiff sought injunctive relief
• Standing
• Relief Granted
6
Allegations of Wrongful Conduct
• Alleged deficiencies in Written Plans
• Allegedly inadequate implementation of
those plans
Development of NPDES/Storm
Water Plans
• Plans are adequate under the law, irrespective
of what standard is applied.
– BAT
– BCT
– MEP
7
Plan Implementation
-Housekeeping• Inspections
• Record keeping
• Corrective action
Inspections
• No permits ever required inspections
• An early version of a SWPPP included a “Daily”
BMP inspection provision
• Inspections conducted during firstshift/weekdays only
8
Record Keeping
• Records were kept for inspections conducted by
Environmental Staff
• Back-shift and week-end inspection/records
were not conducted/recorded in same format
Record Keeping Statistics
• Only 53% of inspections conducted
– This statistic is for the number of inspection
reports in the files for the possible days in
the prior three years (including weekends
and holidays)
9
Corrective Action
• Timely correction of identified problems
– Same or similar deficiencies noted on several
occasions
– Multiple days with same deficiency
• Standing
• Relief Granted
10
Decision/Judgment
• Findings of Fact
– Plan adequacy
– Plan implementation
• Causal Harm
• Standing
• Relief Granted
11
Relief Granted
• Specific Directives
• Penalties
• Enforcement Procedures
• Attorney’s fees
Specific Directives
• Testing
• Sweep-downs/certifications
• Inspections and Record keeping
• Water Column Testing
• Corrective
Action
Southern States
Environmental Conference 2001 Shipyard Track
12
Specific Directives
Physical Plant Improvements
• Shrouds
• Piers
• Berms
Penalties
• Violations for 799 days
• $1,000 per day
• Provisional penalty of $799,000
13
Enforcement
• Oversight
• Reporting Requirement
• Inspections
Attorneys’ fees
• Plaintiffs awarded attorneys’ fees and
expert witness fees
14
Concluding Remarks
• Review the objectives of your inspection program
• Record corrective action
• Implement a records retention policy
• Say what you do, and do what you say in your written
plans
• GoodGood-faith implementation of environmental programs
are insufficient as a matter of law
• This case raises the bar with respect to successful
motion
for States
summary
Judgment.
Discovery/access
to
Southern
Environmental
Conference 2001
Shipyard Track
facility records and site visits are much easier to obtain
15
Shipyard Regulatory Requirements for Stormwater Discharges
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
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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
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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
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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
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Page 4
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
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Page 5
•
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 activitiesfpub1.epa.gov/npdes/stormwater/cgplarge.cfm?program_id=6
•
Small construction activitieshttp://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.
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Page 6
Managing Shipyard
Shipyard Regulatory
Requirements for
Southern States Environmental Conference 2001
Shipyard Track
10/25/01
1
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
Southern States Environmental Conference Shipyard Track
10/25/01
2
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
10/25/01
3
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
10/25/01
4
National Pollutant Discharge
Elimination System
(NPDES)……………..…….?????
• A permitting mechanism that
implements regulatory oversight and
controls on pollutants being
discharged into local waterbodies
10/25/01
5
NPDES requirements
• Obtain coverage under a stormwater permit
• Permit types:
Individual (facility specific)
Multi-Sector General (MSGP)
10/25/01
6
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)
10/25/01
7
• 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
10/25/01
8
• 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)
10/25/01
9
• 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
10/25/01
10
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
10/25/01
11
• 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
10/25/01
12
• SWPPP Guidance document:
www.epa.gov/npdes/pubs/owm0307.pdf
• EPA Office of Waste Water ManagementState link page:
http://cfpub1.epa.gov/npdes/linkresult.cfm
?program_id=6&link_category=2&view=link
10/25/01
13
• Everything you ever wanted to know about
stormwater:
http://cfpub1.epa.gov/npdes/doc/cfm?prog
ram_id=6&view=allprog&sort=name
10/25/01
14
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
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 multimedia 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 selfaudit 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
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
1
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
2
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
3
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
4
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
5
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
6
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
7
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
8
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 Headquarter
www.epa.gov/npdes/stormwater/
EPA Region 4
www.epa.gov/region4/water/wpeb/stormwater
ASCE
www.bmpdatabase.org
9
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
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 nonapplicable 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.
Managing Shipyard
Permitting of Shipyard Stormwater Discharges
“Partnering for the Environment”
Shipyard Track
11/17/2001
1
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.
11/17/2001
2
1
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.
11/17/2001
3
Shipyards
Non-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.
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4
2
Shipyards
Non-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.
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5
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.
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6
3
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”.
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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”.
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4
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.
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9
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.
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5
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”.
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11
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”.
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6
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
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Conclusion
• 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.
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7
Conclusion
• 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.
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15
Questions ?
• Answers
• Comments
• Rebuttals
• Boos & Hisses
• Throwing of
Rotten Tomatoes
11/17/2001
16
8
Shipyard Stormwater Pollutant Sources and Loading
Dana M. Austin
President
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
1
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
Surface Preparation
Coating Application
Processes
Dry abrasive blasting
Hydro washing
Ultra High Pressure Water Jetting
Solvent Cleaning
Bush and roller coating application – exterior and
interior of ship.
Spray application of coatings - exterior of ship.
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.
2
Spray application of coatings - small parts
Flame spray
Metal Working
Cutting, burning of metal structures or parts.
Brazing of metal structures or parts
Welding of metal structures or parts
Grinding of metal surfaces.
Pipefitting
Fabrication of piping systems
Installation of piping systems
Modification of piping systems
Repair of piping systems
Pressure testing of piping systems
Shipfitting
Remove structural materials
Repair structural materials
Installation of structural materials
Layout and Fabrication of structural materials
Sheetmetal
Manufacture of sheetmetal items.
Modification of sheetmetal items.
Repair of sheetmetal items.
Assembly of sheetmetal items.
Machining
Manufacture of machine items.
Modification of machine items.
Repair of machine items.
Assembly of machine items.
Carpentry and woodworking
Insulation
Cutting of wood products.
Milling of wood products.
Sanding of wood products.
Preserving of wood products.
Assembly of wood structures.
Removal of insulation materials.
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
3
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
4
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
5
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
6
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.
7
Figure 1.0
Spent abrasive clean
up
Transport of spent
abrasive to storage
area
Blasting operations
Dust, Spillage
Dust, Spillage
4
5
Dust, Spillage
8
Same as Above
Same as Above
Metals, PM, spent
abrasive
Same as Above
Same as Above
Same as Above
Same as Above
Metals, PM
Pollutant Type(s) of
Concern
Figure 1.1
Dust, spent abrasive
waste
7
Dust, spent abrasive
Spillage from truck
3
6
Dust, Spillage
Dust, Spillage
Emission Type (s)
2
1
Load Slag into
Storage Silo
Load Slag into Trucks
from Silo
Transporting Slag to
work area
Loading Slag from
truck to hoppers
Load Slag into
blasting pots
Flow Chart
No.
Emission Point
Material Input: Copper Slag abrasive
Dry Abrasive Blasting Emissions Points
Same as Above
Same as Above
Coating removal may add new, or
increase loading of metals in dust
and spent abrasive. The amount of
water soluble forms of metals,
derived from the coating being
removed may increased
Same as Above
Same as Above
Same as Above
Same as Above
Metals in virgin copper slag
generally have a low solubility in
water. EF for dust emissions can be
estimated from sieve data. Spillage
of materials during transfer
generally remains in area, but may
be tracked to other areas on the tires
of rolling stock.
Comments
Figure 2.0
O th e r s ( ? )
S e d i m e n ts
G r a v ity D e p o s it io n
S u r fa c e W a te rs
S t o rm W a te r F lo w
S t o rm W a te r O u t fa ll( s )
S t o rm W a te r F lo w
P r o c e s s W a te r F lo w (s )
P r o c e s s W a te r F lo w ( s )
S t o r m W a te r D r a i n ( s )
S t o r m W a te r F lo w
G r o u n d S u rf a c e o f S h i p y a rd
G r a v ity D e p o s it io n
P r o c e s s W a te r F lo w ( s )
A tm . W a s h O u t
D ir e c t D is c h a rg e to A ir
Date:_____________
Page __of __
Dry-abrasive blasting
Blast Pit
Direct to air from substrate being cleaned.
Copper Slag, existing coating being removed, and metal substrate.
Copper slag is accelerated, using compressed air, and impacted against substrate being cleaned.
Particulate matter, metals and possibly others depending on abrasive used and substrate cleaned.
Process:
Location:
Emission Point:
Material Inputs:
Description of process step or point
resulting in emissions:
Types of Pollutant(s) Released:
Figure 2.1
Surface Preparation
Operation:
Pollution Pathway Analysis – Dry Abrasive Blasting
Types of Pollutant(s) Released:
Description of process step
resulting in emissions
Material Inputs:
Emission Point
Location:
Process:
Operation:
Figure 2.1
Pollution Pathway Analysis
Figure 2.1
Date:_____________
Page __of __
Managing Shipyard
Shipyard Pollutant Sources
and Loading
Shipyard Track
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1
Shipyard Stormwater Pollution
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2
1
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?
11/17/2001
3
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
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4
2
and Loading
• Analytical tools, that when properly
applied can:
– Identify the major sources of pollutants.
• By Type
• By Area
• By Discharge
– Prioritize pollution control efforts.
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5
and Loading
• 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.
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6
3
and Loading
• Pollution Pathway Analysis
– Identify sources of pollutants.
– Estimate potential loading of pollutants.
– Determine potential pathways of pollutants to
the environment.
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and Loading
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4
and Loading
• 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 nonshipyard processes.
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and Loading
• 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.
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5
and Loading
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and Loading
• 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.
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6
and Loading
• Estimate Pollutant Loading
– Mass balance equations.
– Pollutant Emission Factors.
– Characteristic Knowledge of Operations and
Processes.
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and Loading
• Pollution Pathways
– How does the pollutant get to the
environment?
• Physical pathways
• Transport Mechanisms
– Each step in the pathway must be identified.
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7
and Loading
• 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?
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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 Compressed air dry abrasive blasting
in emissions
Types of Pollutant(s)
Released:
Copper
8
Date:_____________
Page __of __
Dust emission to air
Gavity Deposition
Surface of Ground
Storm water flow
Storm drain
Storm water flow
Storm water outfall
Discharge from outfall
Surface Waters
Gavity Deposition
Sediments
and Loading
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9
and Loading
– 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.
11/17/2001
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and Loading
– 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.
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10
11/17/2001
21
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, costeffective 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 lowpressure 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
Points of View
• Owner
• Contractor
• Coatings Manufacturer
Driving Forces
• Environmental
Regulations
• Health and Safety
• Economics
• Performance
1
Ave. Lead In Air (ug/m3)
NSRP 0509
Containment –recycled metallic media
3015
HP Waterjetting
9
Low Vol. Slurry
4
Open Air Abrasive
13,439
Small Area Touch up- hand/power tools
680
PEL = 50 ug/m3
Environmental Considerations
• Clean Air Act
• Clean Water Act
Occupational Health & Safety Act
OOSHA
–NIOSH
–Potential Hazards to Workers
2
EPA (initial selection = 43 rules)
Safe Drinking Water
12%
Right-to-know 2%
Clean Water 7%
Toxic Substances
5%
Haz. & Muni.
Wastes 5%
Clean Air 70%
30% Transportation
Clean Air
40% other
Source: C&EN, Sept. 10, 2001, p. 28
Rules impact > $100 million/year since 1993
Pollution Prevention
• Containment
• Processing
• Recycling
3
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?
4
Flow International
Flow International
5
How to Pick Up
Containment Pool
Courtesy- Carolina Equipment & Supply
How to Pick Up
Vacuum Boom
Courtesy – Carolina Equipment & Supply
6
Todd Pacific Shipyard
Baseline Metrics
NSRP- Atlantic Marine
Personal
11%
24%
Nozzle on
Fatigue
24%
Set-up
24%
4%
13%
Based on 53 hours
Delay
Major
Movement
7
How Much Is Generated
Pump
Pressure
Nozzle
Flow
Psi
2,500
gpm
4.3
10,000
# of tips
per
nozzle
Flow Rate per
Tip
1
gpm
4.3
6.83
2
3.4
20,000
4.40
2
2.2
40,000
2.59
5
0.52
Abrasive Injected WB
3.2 gallons per minute
• water only
• water+media (soluble, soft, hard)
• pressures from 15,000 PSI to 40,000
PSI.
8
Bridge (Corrpro Study for FHWA)
• Water Consumption
Structure % area
Water
Water rate
deteriorated Consumed (gal)
Total ft2
(gal/ft2)
44,800
20.0
6,860
0.153
17,820
10.7
2,180
0.122
8,550
5.6
800
0.094
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
9
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
10
Design Requirements
Todd 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
11
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
12
Flow International
Courtesy- Carolina Equipment
13
Pratt & Whitney
Pratt & Whitney
14
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
40
35
30
25
20
ug/cubic meter
15
Average 2.7
10
Non-detect except
5
0
1
3
5
7
9 11 13 15
One sample
15
Blaster Personal Breathing Zone
120
100
80
60
Jetter Air
40
Average 14 ug/m3
20
0
1 3 5 7 9 11 13 15 17 19 21
Detection Limit 20 ug/m3
Action Limit
30 ug/m3
Interior Steel
16
Waste Streams
Water Jetting
• Clarified Water
Abrasive Blast
Abrasive + Paint
• Hazardous Sludge
• Materials Related to Paint
Same
Paint Waste Materials
common to WJ and Abrasive
Blasting
• Waste Paint Thinner
4,000 pounds
• Paint Cans and other Solids
Associated with Paint
pounds
40,000
17
Analysis of Decant Water
TCLP Metals
Component
Arsenic
Barium
Cadmium
Chromium
Lead
Selenium
Silver
Mercury
Results
mg/L
< 0.10
<1.0
<0.10
<0.20
<0.20
<0.10
<0.10
<0.01
Reporting
Limit
mg/L
< 0.10
<1.0
<0.10
<0.20
<0.20
<0.10
<0.10
<0.01
Regulatory
Limit
mg/L
<5.0
<100
<1.0
<5.0
<5.0
<1.0
<5.0
<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
18
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: 1
Estimated Project Savings $500,000
19
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
• Water Jet Hazardous Waste
82 tons
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
20
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)
21
Economic Comparison $/sq foot
Dry Abr.*
UHP WJ# UHP WJ* UHP WJ**
Blast material 0.44
0
0.26
Labor
0.95
Containment
11.04
0
Disposal
3.14
0.78
Other
Total
0.42
$17.15
$5.08
$8.02
$1.63
*1995 Puget Sound Study
**2000 NSRP survey of shipyards (7 doing UHP WJ)
# Ongoing NSRP study- Atlantic Marine
Bridge LBP (Corrpro Study for FHWA)
• Economics
Structure
Size
% area
deteriorated
Hand Tool
cost/ft2
AIWB
Cost/ft2
5,000
20%
12.18
9.38
10,000
20%
7.79
7.02
50,000
20%
5.38
3.78
200,000
20%
4.95
3.26
22
Pollution Prevention
• Containment
• Processing
• Recycling
Thanks
• Norman Morris- Delta 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
23
Alternatives for Control, Collection, and Treatment of
Shipyard Stormwater
Barry L. Kellems1, P.E, Fabian F. Sanchez2, Lynwood P. Haumschilt3
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.
1
Senior Associate, Hart Crowser, Inc., 1910 Fairview Avenue East, Seattle, Washington 98102.
Engineer, Hart Crowser, Inc. 3Consultant, LPH Consulting, 17546 Caminito Balata, San Diego,
California 92128.
2
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 9736. 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
Parameter
Copper in ug/L
Lead in ug/L
Zinc in ug/L
TSS in mg/L
Oil and Grease in mg/L
Puget Sound Shipyard
Influent
Effluent
220
3.1
59
8.1
860
81
40
NR
4
NR
San Diego Shipyard
Influent
Effluent
340
37
90
NR
1,400
300
26
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 fullscale 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 longterm 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
Catch Basin Inserts
Description
Provide inlet protection using
commercially available fabric
or insert type
Swirl Regulators and
Concentrators
Catch basins or treatment units
with inside structure designed
to improve solids and oil
removal and retention
Detention Pond
Lowers runoff velocities and
allows settling of particulate
pollutants
Biotreatment
Bioswales or grass filter strips
lower runoff velocity and acts
as a filter to trap particulate
pollutants
Filter stormwater through sand
filter, trapping particulate
pollutants
Sand Filtration
Enhanced Filtration
Chemical Precipitation and
Sedimentation
Filter stormwater through
enhanced filtration media,
trapping particulate pollutants.
Dissolved metal removal may
be possible
Design system to optimize
reduction in pollutant
concentrations. System may
include ultrafiltration or ion
exchange unit for dissolved
metal removal
Effectiveness
Low: Does not
capture dissolved
pollutants or fine
particulates
Low: Does not
capture dissolved
pollutants or fine
particulates
Low: Does not
capture dissolved
pollutants or fine
particulates
Medium: Limited
effectiveness for
dissolved
pollutants
Medium: Limited
effectiveness for
dissolved
pollutants
Uncertain:
Performance data
limited
High: System
designed to
achieve optimal
removal of
pollutants
Technical Feasibility
Medium: Has excessive
operational
requirements
Screening Results
Eliminated
Medium: Requires
purchase of new catch
basin and/or treatment
system for concentrated
solids
Low: Depends on land
availability. Typical
shipyard has low land
availability
Low: Depends on land
availability. Typical
shipyard has low land
availability
Medium: Requires
redesign of storm sewer
lines and purchase of
filtration unit
Medium: Requires
redesign of storm sewer
lines and purchase of
filtration unit
Eliminated
Medium: Requires
purchase of storage
tanks and treatment
system
Retained for detailed
analysis as baseline
treatment method
Eliminated
Eliminated
Retained for detailed
analysis as baseline
treatment method
Retained for bench-scale
testing followed by
detailed analysis
3
Table 3. Summary of 1997 Bench-Scale Test Criteria and Results (Hart Crowser 2000)
Test
Short-Term High Loading*
Short-Term Low Loading*
Long-Term 500 EBV**
Long-Term 900 EBV**
Unrestricted Flow
Media Sieve Screen Size in Flow Rate in Flow Rate in
Size
Inches
gpm/SF
gpm/CF
#7 to #13
0.11 to 0.06
17
9
#7 to #13
0.11 to 0.06
13
7
#14 to #30 0.055 to 0.023
14
14
#14 to #30 0.055 to 0.023
14
14
Controlled Flow
Average Flow
Average Flow
Rate in gpm/SF Rate in gpm/CF
3.3
1.7
2.4
1.2
2
2
2
2
Removal Rate in Percent
Copper
50
49
97
97
Lead
28
23
82
95
Zinc
83
85
94
71
* 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
TSS
44
38
NM
NM
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 belowground, 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 organicbased 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
Managing Shipyard
Alternatives for Control, Collection,
and Treatment of Shipyard
Stormwater
Barry Kellems
Hart Crowser, Inc.
Delivering smarter solutions
Shipyard Track
11/18/2001
1
Increased Regulation
• Increasingly Stringent Discharge
Limitations under NPDES
• Copper and Zinc Typically Control
• Toxicity Standards Becoming More
Prevalent
11/18/2001
2
1
Shipyard Stormwater Influent Characteristics And
Discharge Requirements
P aram eter
C opper
P uget Sound Shipyard
Influent(1)
E ffluent
(2)
220 ug/L
3.1 ug/L
San D iego Shipyard
Influent(3)
E ffluent (4)
340 ug/L
37 ug/L
L ead
59 ug/L
8.1 ug/L
90 ug/L
NR
Z inc
T SS
860 ug/L
40 m g/L
81 ug/L
NR
1,400 ug/L
26 m g/L
300 ug/L
NR
4 m g/L
NR
8 m g/L
25 m g/L
O il and G rease
(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 Q uality Standards For Surface
W aters O f The State O f W ashington (C hapter 173-201A W A C ) and are
based on chronic toxicity.
(3) Influent concentrations are the average for drainage SW -3 at the
N A SSC O shipyard in San D iego, C alifornia.
(4) Effluent requirem ents calculated using the influent concentrations (3)
and toxicity discharge requirem ents in C A R W Q C B San D iego R egion
O rder 97-36. O il and G rease lim itation based on a 30-day average.
N R = N ot explicitly regulated.
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.
11/18/2001
4
2
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
11/18/2001
5
Stormwater Treatment
Alternatives
• Evaluation Conducted for Puget Sound
Shipyards in 1997
• Screening of Technologies Based on
Effectiveness and Technical Feasibility
Indicated that Enhanced Filtration (OrganicBased) Would be Viable
• Screening of Filtration Media Indicated that
CSF Humic (Leaf Compost) Filter Media and
Others Warranted Testing
11/18/2001
6
3
4
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%
11/18/2001
9
5
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%
6
Cost Analysis
• Economic Reasonability Test
• Enhanced Filtration Most Cost Effective
• Data Gap = Full-Scale Performance
Under Dynamic Conditions
11/18/2001
13
7
Demonstration of
Enhanced Filtration
• NSRP Sponsored Project at NASSCO Shipyard
• Test Three Grain-Size Distributions of Compost
Media During Multiple Storms
• Treat 95% of the Runoff from Approximately
10 Acres
• Design Completed 2000
• Construction Completed 2001
• First Test (Artificial Storm) September 2001
11/18/2001
15
8
9
10
11
Self-Cleaning Filter Cartridge
12
13
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.
11/18/2001
27
14
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
O&G
COD
TSS
BOD
pH
Conductivity
Chlorine
TKN
Nitrate
Nitrite
Phosphate
Sulfate
Sulfite
Chloride
Cyanide
Volatiles (VOC)
TCE
Vinyl Chloride
Other chlorinated solvents
Brominated compounds
BTEX compounds
MTBE
DRO – Diesel Range Organics
GRO - Gas Range Organics
Metals
Dissolved
Totals - TCLP
Mercury
Semi-volatiles (SVOC)
PAH - Polyaromatic Hydrocarbons
TPH - Total Petroleum Hydocarbons
Herbicides
Pesticides
Acid-Base Neutrals (ABNs) - N/A
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
1
Skoog, Douglas A. & Leary, James J.; Principles of Instrumental Analysis, 4th Edition; 1992;
658.
4
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) 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
255
3
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
4
236.
7
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
Laboratory Analysis of
Stormwater
Jason Mennino
Northrop Grumman Ship Systems
Ingalls Operations
09/27/01
Southern States Environmental
Conference 2001 Shipyard Track
1
Why should you care??
• Proof of compliance
– MSGP
– Individual permit
• Background studies for new permits
• Integrity/Accuracy
– Laboratory
– Results
09/27/01
2
1
Common Stormwater Parameters
•
•
•
•
•
•
•
Oil & Grease
COD
TSS
BOD
pH
VOCs
Metals
• Conductivity
• Inorganics
–
–
–
–
–
–
–
– Zn
– Cu
09/27/01
NO3
NO2
Cl2
CN
SO4
SO3
Chloride
3
Sampling
• Containers
– glass v. plastic
– amber v. clear
•
•
•
•
•
Hold time issues
Preserved v. Unpreserved
Refrigeration
Sample size/quantity
Grab v. composite
– auto samplers
09/27/01
4
2
Transport to Lab
• Chain of Custody
– Must be signed
• Refrigeration
– Cooler w/ice packs
• Courier
• Other shipping means
09/27/01
5
Samples arrive at laboratory
• Sign COC
• Sample Distribution
– Release legal custody
• Sample login
– Unpack cooler
– Sample inspection
– Match samples to COC
• # of samples
• sample ID’s
– Parameter delineation
• hold time issues
09/27/01
– Wet Chem lab
– Metals lab
– Semi-Volatiles
(SVOCs) lab
– Volatiles (VOC) lab
– Microbiology lab
• Usually N/A for
stormwater
6
3
Wet Chem Lab
• Parameters
–
–
–
–
–
–
–
–
–
• Inorganics
Oil & Grease
COD
TSS
BOD
pH
Conductivity
Chlorine
TKN
CN
–
–
–
–
–
–
–
09/27/01
NO3
NO2
PO4 - ortho
SO4
SO3
SO2
Chloride
7
Metals Lab
• Dissolved
• Totals
– TCLP
• Mercury (Hg)
09/27/01
8
4
Semi-volatiles (SVOC) Lab
•
•
•
•
•
PAHs - Polyaromatic Hydrocarbons
TPH - Total Petroleum Hydrocarbons
Herbicides
Pesticides
Acid/Base Neutral (ABN) - N/A
09/27/01
9
Volatiles (VOC) Lab
•
•
•
•
•
•
•
•
TCE
Vinyl chloride
Other chlorinated solvents
Brominated compounds
BTEX compounds
MTBE
DRO - Diesel Range Organics
GRO - Gas Range Organics
09/27/01
10
5
Analysis Technologies
• Chromatography
– Ion Chromatography (IC)
– Gas Chromatography (GC)
•
•
•
•
Inductively Coupled Plasma (ICP)
Atomic Absorption (AA)
Other
09/27/01
11
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
09/27/01
12
6
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)
09/27/01
13
Ion Chromatography (IC)
•
•
•
•
Liquid Chromatography
Widely utilized in most labs
Anion analysis
Wet Chem lab
09/27/01
14
7
IC Analytes
•
•
•
•
•
•
•
•
•
Acetate
Azide
Bromate
Bromide
Chlorate
Chloride
Cr(VI)
Fluoride
Iodide
09/27/01
•
•
•
•
•
•
•
•
Nitrate
Nitrite
Oxalate
Perchlorate
Phosphate
Sulfate
Sulfite
Sulfonic Acids
15
16
8
17
Gas Chromatography
• Used in SVOC lab
– Methylene Chloride extraction
– Used to use Freon
• Used in VOC lab
– No extraction
– Purge & trap
09/27/01
18
9
19
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.
09/27/01
20
10
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 !!
09/27/01
21
Thermal Conductivity Detector
09/27/01
22
11
23
Photoionization Detector
09/27/01
24
12
Electron Capture Detector
09/27/01
25
*Table 2. Comparison of Saturn System MDLs with Current and (Proposed) MCLs
2,3
Compound
MCL(ppb)
Saturn System MDL
Benzene
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.
09/27/01
26
13
• 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
–
–
–
–
09/27/01
Wagging
Rocking
Scissoring
Twisting
27
28
14
IR cont’d
• Typically used for organics
– e.g. TPH
• Spectra library developed
– compare spectra to determine constituents
09/27/01
29
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
09/27/01
30
15
32
16
33
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)
09/27/01
34
17
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
09/27/01
35
Courtesy of University of Akron Chemistry Department
36
18
Quality Assurance/Quality
Control (QA/QC)
• Laboratory SOPs
– Standard Operating
Procedures
(methodology)
• % Recovery
• Chain of Custody
• Matrix Spikes
– duplicates
• Blanks
– duplicates
– laboratory
– field
09/27/01
38
19
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.meeinc.com
09/27/01
39
20
Speaker Biographies and
Presentation Abstracts
LEGAL REQUIREMENTS FOR SHIPYARD STORM WATER DISCHARGES
By:
Joseph Green, Senior Associate and John L. Wittenborn, Partner
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 facilityspecific ("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 SUITES
A CASE STUDY
By:
Sandor (Shaun) Halvax
Manager of Material Business Management
Southwest Marine, Inc.
P.O. Box 13308
San Diego, CA 92170-3308
(619) 238-1000
[email protected]
Tuesday, 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 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.
Biographical Sketch
Shaun is currently employed with Southwest Marine, Inc. and is charged with developing and implementing
environmental programs for three shipyards in California. He has been employed by Southwest Marine
for the past five years. Prior to Southwest Marine, Shaun was employed by Continental Maritime of San
Diego 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 Engineering
Contractors License with the State of California.
Shaun’s education includes a Bachelor of Science in Production and Operations Management, a Bachelor
of 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 Compliance
Friede/Goldman/Halter
PO Box 3029
Gulfport, MS 39505
(228) 896-2644
[email protected]
Tuesday, 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 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; a loss in aesthetic value in addition to the possibility of threatening public
health.
Storm water discharges from shipyard and ship-repair facilities is 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.
In addition to the regulatory requirements, the ‘Shipyard Regulatory Requirements for Stormwater
Discharges’ presentation will demonstrate shipyard stormwater permitting processes and procedures,
incorporate methodologies to control storm water discharges through the use of best management practices
and contain a mixture of significant web-links that will allow attendees to research stormwater regulations
as 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 of
Environmental 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 Industries
Program/Technical Advisory Panel regarding the ‘Environmental Management Systems Template for the
Shipbuilding & Ship Repair Industry’. He also is the current Chairman of the Board for the ‘Shipyard
Association for Environmental Responsibility’ (SAFER) which is principally a Gulf of Mexico wide
shipbuilding/ship repair trade organization that addresses regional industry environmental issues and the
impact/outcome of these regulations upon the industry. Patrick also is, and has been a member of the
National Shipbuilding Research Program (NSRP) environmental technical advisory panel, SP-1, since
1996.
Kwan 1
AGENCY ENFORCEMENT OF SHIPYARD STORMWATER DISCHARGES
By:
Kenneth Kwan
US Environmental Protection Agency, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
(404) 562-9752
[email protected]
Wednesday, September 26, 2001 10:00 - 11:30 AM
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.
Biographical Sketch
Kenneth is the Storm water enforcement expert for EPA Region 4. In this capacity, he oversees the storm
water enforcement for eight southeast states. Kenneth also has over 15 years of experience in the
enforcement of industrial and municipal wastewater treatment facilities. Kenneth received a Bachelor of
Civil Engineer degree from Georgia Institute of Technology. He is a Registered Professional Engineer in
the State of Georgia.
Holt & Maher 1
STORMWATER PERMITTING OF SHIPYARD STORMWATER DISCHARGES
By:
Wayne S. Holt
Director Safety/Environmental
Atlantic Marine, Inc./ Atlantic Dry Dock Corp
8500 Heckscher Drive
Jacksonville, FL 32226
(904) 251-1582
[email protected]
And
Jim Maher
Supervisor of Industrial Wastewater for the Northeast District
Florida Department of Environmental Protection
7825 Baymeadows Way Suite B200
(904) 807-3300
[email protected]
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 present 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
Holt & Maher 2
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.
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 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 it’s 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 facilities. This experience and expertise is indispensable in assisting the facility in orienting
it approach toward stormwater management.
A collaborative, systematic and comprehensive investigation of all aspects of a facility that has the
potential 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 a
feel 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 agreement
with the contents, thus avoiding the litigation that is often quite common in after-the-fact permit
negotiations. 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.
Biographical Sketch
Wayne is the Environmental and Safety Director for Atlantic Marine, Inc. and Atlantic Dry Dock
Corporation 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 related
issues. Wayne received a Bachelors of Science degree in Architectural Engineering from Florida
A & 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 of
Environmental Professionals. Wayne is a member of the National Association of Environmental
Professionals, the American Society of Safety Engineers, and the American Society of Naval
Engineers. Additionally, he is a certified OPA-90 Qualified Individual, and certified both as a
Marine Fire Fighter and a Competent Person by the National Fire Protection Association. Wayne
also holds an Asbestos Air Monitoring Lab certification through the American Industrial Hygiene
Association. In addition to performing his duties at Atlantic, Wayne is the Chairman of the First
Coast Manufacturers Association Environmental, Health, and Safety Committee and has served
as a Project Manager for a variety of environmental projects being performed through the National
Shipbuilding Research Program.
Jim is the Supervisor of the Industrial Wastewater Section for the Northeast District office of the
Florida Department of Environmental Protection (FDEP). He has been with FDEP for 12 years
after serving in the US Navy. Jim received a Bachelor of Science degree in Chemical Engineering
from Lehigh University and a Masters of Business Administration from the University of North
Florida. At FDEP he is responsible for administration of NPDES program for surface water
discharges from paper mills, power plants, chemical plants, dairies, and various other industries.
Additional duties include Domestic Wastewater NPDES permitting; funding development for
wastewater facility upgrades; development of TMDLs and is the agency representative for efforts
to fully restore the St. Johns River. He served as chairman of a St. Johns River Task Force and
is an agency representative on the Governor’s Harmful Algae Bloom Task Force and assists in the
development of NPDES inspector training. Jim is a Registered Professional Engineer in the State
of Florida. He also does software programming for a Financial Valuation company.
Austin 1
SHIPYARD STORMWATER POLLUTANT SOURCES AND LOADING
By:
Dana M. Austin
President
PMB 233, 450 State Road 13 North, Suite 106
(904) 287-1034
[email protected]
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, to determine where Best Management Practices to control the discharges can be
applied.
This paper examines several common shipyard operations and processes to determine the types of
pollutants 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 process
can be applied by the shipyard environmental manager 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.
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
INDUSTRIAL ENVIRONMENTAL MANAGER
1991 - 1995
1989 - 1991
Provided leadership in planning, directing and overseeing corporate and divisional industrial operations compliance with
environmental protection regulations. Directly accountable for 4 major company divisions; advise management personnel
in regulatory interpretation, implementation and liability issues; supervise all technical operations.
Austin 2
CHEMICAL SAFETY ASSOCIATES, INCORPORATED
SENIOR ASSOCIATE
ASSOCIATE
1987 - 1989
1985 - 1987
Provided environmental and chemical safety consulting and training services while developing business within a national
client 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 and
instructed client personnel in customized safety, regulatory and emergency response programs.
ECOSYSTEMS MANAGEMENT ASSOCIATES, INCORPORATED
CHEMICALPROJECTS MANAGER
CHEMIST / RESEARCHER / DIVER
1984 - 1987
1982 - 1984
Headed project execution for this environmental consulting enterprise focused on near shore ocean processes including
marine geology, chemistry and physical oceanography. Directed field personnel in collecting samples; enforced sampling
protocol 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 ASSOCIATION
Member, Environmental Committee: SHIPBUILDERS COUNCIL OF AMERICA
Member, Facilities and Environmental Effects Panel: SOCIETY OF NAVAL ARCHITECTS AND MARINE ENGINEERS
Board of Directors _ Chairman, Environmental Committee: SAN DIEGO PORT TENANTS ASSOCIATION
EDUCATION
Certification in Air Quality Management, 1994: University of California at San Diego Extension
Certification 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 Diego
Bachelor of Science in Biochemistry, 1973: University of California at Irvine
Frenzel 1
HYDRO BLASTING AND WATERJETTING IN THE MARINE CONSTRUCTION
INDUSTRY AS RELATED TO WASTE MINIMIZATION AND POLLUTION
PREVENTION
By:
Lydia M. Frenzel, Ph.D.
Executive Director
Advisory Council
PO Box 2139
San Marcos, TX 78667
512-392-2210
[email protected]
www.advisorycouncil.org
www.waterjetting.org
Thursday, September 27, 2001 10:30 AM - 12:00 N
Hydro Blasting and Water-Jetting in the Marine Construction Industry “Renewing America with Renewable
Resources”. 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 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 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 watterjetting compared to storm water run-off.
Biographical Sketch
50 publications, 45 presentations at meetings
Executive Director of the Advisory Council
Ph.D. 1971- University Of Texas at Austin
Recipient 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, VicePresident- 1999- to present
Chair of the SSPC- NACE Wet Abrasive Blast and Water Jetting Standards Task Groups
NACE representative to ISO Waterjet Working Group
Past 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 SHIPYARD
STORMWATER
By:
Barry L. Kellems, P.E.
Senior Associate
Hart Crowser, Inc.
1910 Fairview Avenue East
Seattle, Washington 98102-3699
[email protected]
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.
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.
The presentation describes and summarizes the advantages and disadvantages of the various alternatives
for managing stormwater at shipyards. Treatment performance and cost data show the relative effectiveness
and implementability of infiltration, diversion to the municipal sewer, and physical-chemical treatment versus
organic-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 Oregon
State University and a Master of Science degree in Environmental Engineering from Cornell University.
Mennino 1
LABORATORY ANALYSIS OF STORMWATER
By:
Jason Mennino
Ingalls Shipbuilding
PO Box 149, M/S 8021-01
Pascagoula, MS 39568-0149
(228) 935-3388
[email protected]
Because all shipyards are required to have an NPDES permit, some sort of monitoring program
must 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 happens
to these stormwater samples once they reach the lab can be a bit of a mystery. This presentation
will clarify the process from sample collection to analysis.
It will include some sampling requirements and techniques. The technologies, from GC/MS to a
simple 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 often
misunderstood by those outside of the laboratory environment. Finally, an explanation for the
ramifications 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. Prior
to working at Ingalls Shipbuilding, he was a Research Scientist/Project Manager for YSI Inc. in
Yellow Springs, Ohio. As a part of their Environmental Products Group, he assisted in the design
and 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 laboratory
analyses, he performed a variety of tasks including sanitary sewer, landfill and stormwater sampling

Managing Shipyard Stormwater Discharges

Transcription

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