Modern Medicine: Stormwater Antidotes for Galvanizers. (800)

Transcription

1 Modern Medicine: Stormwater Antidotes for Galvanizers (800)

2 Outline Regulatory climate and why it matters now Stormwater pollution control for galvanizing plants Minimizing your risk medic s s report from the front line Take-home BMPs

3 Zinc - Ubiquitous in the Urban Environment Hydraulic 0.11% zinc 1.5% 0.1% Macronutrient Infrastructure Typically not very mobile

4 Any reason for Concern? Brew Pub Parking 0.01 mg/l zinc 10.0 mg/l zinc Steel Pipe 0.5 mg/l zinc Office Parking mg/l zinc Residential Road mg/l zinc

5 Recent Permitting Development: State Listing of Impaired Waters

6 Any reason for concern Number of rivers impaired by zinc = more stringent stormwater permits in the near future. US EPA Website:

7 NPDES Stormwater Controls

8 NPDES Stormwater Controls

9 NPDES Stormwater Controls

10 NPDES Stormwater Controls

11 NPDES Stormwater Controls

12 Converging Regulatory Programs Oil Pollution Act Requirements Lawsuits ESA Lawsuits TMDLs Industrial Permits Lawsuits ESA ESA Lawsuits Municipal (MS4) Permits Regulators (EPA, State, City) Construction Permits (Land Disturbance) Lawsuits TMDLs TMDLs Lawsuits ESA

13 Agency Enforcement Strategy Emphasis changing from "outreach and compliance assistance" to "targeting potential enforcement candidates" Priority: industrial stormwater dischargers Weak documentation Discharges above the mean for priority pollutants

14 Strategy for Not Being a Target Have a permit Submit reports on time Have records organized, available on no-notice Hard Copy = Proof Implement BMPs Drop your numbers to look like neighboring industry

15 How to Drop Your Numbers Operational review fresh eyes Rank On: 1. Zinc reduction effectiveness mass balance 2. Implementation effort - qualitative 3. $$$$

16 Pollutant Sources at Galvanizing Plants Yard Load / Unload Hydraulic equipment leaks, tire wear, brake dust, storage areas and worn containers Finished Product Depends on environmental conditions Maintenance and Repair Vehicle washing, fueling, maintenance and repair areas, ship painting, stripping, engine repair Building Exhaust / Ash Zinc Oxide Zinc Ammonium Chloride Bag House Even 90% efficiency is 10% to the environment Dross / Haz Waste Storage Thread De-Burr Edge Finish / Griding Patching / Cold Galvanizing Chemistries

17 Typical Pollutants at Galvanizing Plants Source Suspended Solids Oil & Grease Metals Other Yard Load / Unload X X X Engine fluids Unfinished Product X Finished Product X Vehicle Maintenance, Storage X X Kettle Exhaust / Wet Process Fume X X Acid Dross / Waste X X X Haz.. Materials De-burr / Finishing X X Patching X VOC (solvents)

18 Real Life Example: Galvanizers No Silver Bullet Hierarchical List Implement over time, schedule in SWPPP

19 Low Fruit: Particulate Zinc Cheapest and most effective way to get your zinc numbers down

20 Zinc and Rainfall Best Friends 5,000 $$ mg/l? Zinc Solubility Soluble Zinc mg/l Natural rainfall ~5.5 ph, Geography dependent ph (standard Units) Based on Zn(OH) 2 Speciation ksp 1.2x and initially pure water

21 Source Control BMPs: Operational Sweeping Covered Storage Spill Prevention Sump Cleaning

22 Real BMP#1 - Limit Exposure Consider high risk activities Grinding Finishing Beam / Parts Storage Waste Handling / Storage

23 Real BMP#2 - Sweeping Removes Particulate Zinc BEFORE it rains Grinding Finishing Beam / Parts Storage Waste Handling / Storage Galvanizing Industry Examples: Plant #1: 30 mg/l 10 mg/l Plant #2: 45 mg/l 12 mg/l

24 Real BMP#3 - Treatment Cost Catch Basin Inserts Other Passive Active Control Performance Catch Basin Inserts Other Passive Active Catch Basin Inserts Other Passive Active

25 Treatment: Catch Basin Inserts Recommended Uses: Very light loading Primarily TSS Isolated use Removal Mechanism: Straining through fabric or screens, some include absorbents Target Pollutants: Trash and debris, some sediment Performance: Coarse solids, dependent on opening size Galvanizing Industry Example: 45 mg/l 45 mg/l

26 Treatment: Wet Ponds, Dry Ponds Definitions: Wet Ponds permanent pool Dry Ponds empty between events Recommended Uses: Reduce swings in concentration Detain first flush Temperate climate Removal Mechanism: Flow attenuation, gravity settling, infiltration, bio. treatment (wet) Target Pollutants: TSS, particulate metals, oil and grease, organics Galvanizing Industry Example: 15 mg/l 10 mg/l

27 Treatment: Filtration Many choices on the market Integrated filter medias remove soluble and particulate metals, neutralize ph Proprietary and custom designs Proprietary: typically designed for urban, non-industrial loads; prefabricated Non-proprietary/custom: more flexible, higher zinc reduction possible, use plant labor and materials if desired

28 Now any reason for concern? Brew Pub Parking 0.01 mg/l zinc Galvanizer with 2 mg/l zinc Steel Pipe 0.5 mg/l zinc Office Parking mg/l zinc Residential Road mg/l zinc

29 Summary: Recommendations Keep your paperwork in order: SWPPP, and updates Monitoring and inspection results Show progress toward benchmarks Focus on red flags Make a strong showing at the fenceline housekeeping and BMPs Upgrade yard infrastructure and stormwater controls Water quantity and quality

30 Where to Get Help Ask Other Galvanizers (AGA) Consulting Engineers Product Manufacturer Referrals Legal Counsel

31 Thank You! StormwateRx LLC