Advisory Council

April 5, 2009

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Partnering for the Environment

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.

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.

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.

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.

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.

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

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April 5, 2009

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Managing Shipyard Stormwater

Shipyards are facing increased regulation of stormwater discharges through the National Pollutant Discharge Elimination System (NPDES) permitting process.

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.

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.

Recently, pilot-scale testing of organic-based filtration has proven to be a more economical treatment alternative.

The results of the screening survey indicated that organic-based enhanced filtration would be a viable alternative to remove metals from shipyard 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.

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.

Influent concentrations are the average for six representative shipyards located in the Puget Sound region of Washington State.

Effluent requirements from “Water Quality Standards For Surface Waters Of The State Of Washington (Chapter 173-201A WAC) and are based on chronic toxicity.

Influent concentrations are the average for drainage SW-3 at the NASSCO shipyard in San Diego, California.

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April 5, 2009

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Pollutants in Storm Water Discharge

[Download not found]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.

The flow chart indicates both the steps in the process, and where in those steps pollutants may be released to the environment.

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.

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.

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 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.

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.

April 5, 2009

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Clean Water Act and Runoff

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.

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.

With that, most storm water discharges are considered point sources and therefore require coverage by a National Pollutant Discharge Elimination System (NPDES) permit.

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.

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.

certain circumstances where a general permit is either not available or not applicable to a specific facility.

Individual permits are issued at the discretion of the NPDES permitting authority.

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April 5, 2009

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Techniques Used in Environmental Labs

Because some analytes are light sensitive, samples must be placed in an amber container rather than a clear one.

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.

Hydrogen ion concentration (pH), for example, must be analyzed immediately whereas O&G can sit on the shelf for 28 days or less.

Ion Chromatography (IC) is a method of liquid chromatography that is conducted in the Wet Chemistry lab.

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).

The electron stream is then sent through a polarization circuit, which sees a current.

The sample is atomized in one of two ways, either through flame atomization or flameless atomization.

The AA is used for Mercury analyses because of the minute detection limits.

As mentioned above, the atomizer of choice is the graphite furnace.

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 first three points prove the lab can perform the analyses with good repeatability and meet the minimum detection limit.

The QA/QC plan will contain the aforementioned elements but will also include lab SOPs (Standard Operating Procedures).

— Utilizes flame (H2 + air) which ionizes organic compounds into e- & positive ions.

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April 5, 2009

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Storm Water Enforcement Strategy

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.

The focus was on major municipal wastewater treatment plants and industrial facilities which have discharges of over one million gallons per day.

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.

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.

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.

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.

The goal of EPA’s inspection program is to be pro-active.

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.

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