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Inspecting Industrial/Commercial Facilities For Pollutants Of Concern

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1 Inspecting Industrial/Commercial Facilities For Pollutants Of Concern
Welcome. This training is being done to meet new requirements in the Municipal Regional Stormwater Permit (MRP). This presentation was developed by BASMAA and customized for our program. BASMAA also developed a Guidance Manual as a companion to this training material. This training material was developed to assist stormwater inspectors identify three pollutants of concern, mercury, PCBs and Copper at commercial and industrial businesses. Insert pictures representing Hg, Cu and PCB

2 Presentation Overview
Regulatory Requirements Pollutants of Concern Copper Mercury PCBs Inspection Forms In this training we will cover the new inspection requirements for copper, mercury and PCBs, in the MRP. Then for each pollutant of concern we will review the regulatory background, facilities & sources, BMPs and any additional requirements. The last topic will be documenting inspection findings using inspection forms. 2

3 Regulatory Requirements
Stormwater Municipal Regional Permit Provision C.11 Mercury Controls Provision C.12 Polycarbonated Biphenyls (PCBs) Controls Provision C.13 Copper Controls BASMAA Regional Training Materials Guidance Manual for SW Inspectors Two of the MRP provisions (PCBs and Copper), explicitly have requirements (sub-provisions) related to identifying POCs during commercial/industrial business inspections, which are required under provision C.4 (Commercial and Industrial Site Controls). The third provision (Mercury Controls) does not explicitly require the identification of mercury and mercury-containing devices during inspections, but it does require the promotion, facilitation and/or participation in the collection and recycling of mercury containing devices. The Guidance Manual developed by BASMAA for stormwater inspectors has supporting material for each POC to help inspectors meet the MRP requirements. 3

4 Pollutant of Concern COPPER

5 Copper POC since the late 1980s.
SF Bay listed as impaired by copper in 1989 Government agencies and businesses made significant investment in copper source identification and copper reduction measures As of July 2003, all San Francisco Bay segments listed for copper have been removed from the State’s 303(d) list of impaired water bodies and placed on the monitoring list Site Specific Objectives (SSOs) adopted Jan 2009 In the aquatic environment, phytoplankton are among the most sensitive organisms to copper toxicity. Phytoplankton form the base of the food chain in most aquatic systems and therefore support higher trophic levels. In 1989 the San Francisco Bay was listed as impaired by copper on the federal 303(d) impaired waterbody list. Since that time, government agencies and business made significant investments in copper source identification and copper reduction measures. As of July 2003, all of the San Francisco Bay segments previously listed for copper were removed from the State’s 3030(d) list of impaired water bodies and placed on the monitoring list. There was also work done to develop site specific objectives (SSOs) for copper. These were adopted in the San Francisco Bay Regional Water Quality Control Board’s Basin Plan in January The SSOs were adopted with an Implementation Plan. Provision C.13 Copper Controls was included in the MRP to “implement the control measures identified in the Basin Plan amendment necessary to support the copper site specific objectives in the San Francisco Bay.”

6 Sources of Copper in Stormwater
Vehicle brake pads Copper air emissions Architectural copper Industrial copper use Improper discharge of pool and spa water Potable water discharged to storm drains Soil erosion Copper pesticides Sources of copper in sotrmwater runoff to San Francisco Bay have been identified as vehicle brake pads, copper air emissions, architectural copper, industrial copper use, improper discharge of pool and spa water, potable water discharges to storm drains, soil erosion and copper pesticides.

7 Provision C.13 Copper Control
Identify commercial/industrial businesses likely to use copper or have sources of copper and include them in the inspection programs Inspectors need to ensure that proper BMPs are in place to minimize discharge of copper to storm drains Special emphasis on roof runoff that might accumulate copper deposits from on-site ventilation systems at industrial businesses The MRP Provision C.13 Copper Control focuses on the industrial sources of copper in stormwater runoff. The MRP requires stormwater programs to 1) identify facilities likely to use copper or have sources of copper and include them in inspection programs; 2) have inspectors ensure that proper BMPs are in place to minimize discharge of copper in stormwater; and 3) as part of industrial inspections of metal finishers and electroplaters include consideration of roof runoff that might accumulate copper deposits from ventilation systems. 7

8 Industrial/Commercial Sources
Electroplating Semiconductor manufacturing Metal finishers Auto dismantlers Car Washes Automotive Services The Guidance Manual lists industrial sources of copper by SICs. The sources of copper at these types of facilities are noted in the guidance manual with the appropriate BMPs. Current inspection practices and implementation of BMPs (e.g., good housekeeping, secondary containment for chemical storage, etc.) will meet most of the MRP’s requirements to ensure that proper BMPs are in place to minimize the discharge of copper in stormwater.

9 Copper in Roof Runoff Metal finishing, electroplating and semiconductor manufacturing industries Processes - copper chloride etchers, ammonia etchers, and acid plating bath exhaust vents This training, and the BASMAA guidance manual, highlight the potential source of copper from roof runoff and the appropriate BMPs for controlling this source. Studies conducted by the Cities of San Jose and Sunnyvale show that metal finishing and electroplating processes contributed (through air and roof deposition) greater amounts of copper and nickel to stormwater runoff than other industrial and commercial activities. Processes at these facilities such as copper chloride etchers, ammonia etchers and acid plating baths could potentially release droplets of copper-containing solutions into building air exhaust systems and out onto building roofs and the surrounding area. 9

10 Inspection for Copper Deposition
Look for chemical deposition around vents, pipes, and other roof surfaces to determine if there is a potential source of copper. If discolorations or deposits are seen, implement BMPs to minimize the contamination of roof runoff. If you are at a business that has these processes ask if you can inspect the roof or if facility personnel can safely inspect the roof. Look for chemical deposition around vents, pipes and other roof surfaces to determine if there is a potential source of copper. You can also inspect the roof downspouts. If discolorations or deposits are seen, or if you are unable to inspect the roof/downspouts, verify that the facility is implementing BMPs to minimize the contamination of roof runoff. 10

11 Best Management Practices
Install vent covers and drip pans Prevent leaks in pipe fittings and containment vessels with routine maintenance Properly dispose of condensate from ventilation Promote condensation of ammonia etchant vapor Install scrubber system to treat ammonia etchant vapors BMPs can include: Install vent covers and drip pans where there are none. Vent covers provide a surface for condensation of exhaust vapors and help prevent rain from entering the system. Prevent leaks in pipe fittings and containment vessels with routine maintenance Properly dispose of condensate from the exhaust ventilation system. Condensation in the drip pan should be plumbed to the waste treatment system or emptied into it manually. If ammonia etchant vapor is escaping into the atmosphere and condensing on the roof, consider promoting condensation within piping containment, such as using chiller coils at the junction of the ammonia etcher and the exhaust vent. This may also help reduce chemical loss. Ammonia etchant vapors can be treated using a scrubber system. The effectiveness of the scrubber system depends on the type of scrubber solution used, and plain water appears to be ineffective. Check that your scrubber solution is appropriate for the chemistry of the fumes. A dilute sulfuric acid solution seems to be the most effective means of treating exhaust vapor from an ammonia etcher. 11

12 Pollutant of Concern MERCURY

13 MERCURY San Francisco Bay is considered to be “impaired” by mercury because some types of fish caught in the Bay contain mercury at concentrations that may threaten the health of humans consuming them. TMDL adopted in SF Bay Basin Plan Feb 2008 Mercury released into the environment (through industrial processes or breakage of mercury containing materials) is transported by air, rain, snow or runoff and deposited in our creeks and Bay. Bacteria convert it into a form that is easily absorbed by microscopic animals and plants, which in turn are consumed by larger animals. San Francisco Bay is considered to be “impaired” by mercury because some types of fish caught in the Bay contain mercury at concentrations that may threaten the health of humans consuming them. A Total Maximum Daily Load (TMDL) was adopted in the Basin Plan February The TMDL includes an Implementation Plan. Provision C.11 Mercury Controls was included in the MRP to “implement the urban runoff requirements of the San Francisco Bay mercury TMDL”.

14 Provision C.11 Permittees shall promote, facilitate, and/or participate in collection and recycling of mercury containing devices and equipment at the consumer level Provision C.11.a. requires Permittees to promote, facilitate, and/or participate in collection and recycling of mercury containing devices and equipment at the consumer level. This training identifies ways inspectors may provide commercial and industrial businesses that have mercury containing devices with the proper BMPs for disposal and spill cleanup.

15 Industrial/Commercial Sources
Facilities that use mercury in processes and equipment metal finishing/electroplating facilities auto dismantlers/recyclers. Facilities that have mercury containing products that need to be disposed properly. There are facilities that use mercury in processes and equipment. Current inspection practices should ensure that proper BMPs (e.g., good housekeeping, secondary containment, etc.) are in place at these facilities to minimize the discharge of mercury to storm drains. For most industrial/commercial facilities the emphasis will be on providing information on the proper disposal of mercury containing Universal Wastes. Inspectors should determine if any of the commercial or industrial facilities they are inspecting have mercury containing products and if the facility contact knows the proper way to dispose of these products. The Universal Waste Regulation is a state regulation that requires proper recycling of hazardous waste. The EPA chose the word “universal” to describe the nature of certain widely dispersed hazardous wastes. These include batteries, mercury thermostats and fluorescent lamps.

16 Mercury Containing Products
Fluorescent Bulbs Tubular and Circuline lamps Compact Fluorescent bulbs Tanning Lamps Germicidal Lamps High Intensity Discharge (HID) Lights These are examples of lamps that contain mercury and would be subject to Universal Hazardous Waste rules if threshold amounts are not exceeded (which will be described further in a minute). Metal Halide lamp Mercury Vapor Lamps High Pressure Sodium Lamps Source: Northeast Waste Management Official’s Association (www.newmoa.org)

17 Mercury Containing Products
Other Types of Lighting Mercury Short Arc Metal Halide Lamp Mercury Xenon Short-arc Lamps These pictures are also in the Guidance Manual for your reference in the field if needed. Mercury Capillary Lamps Neon Lights Source: Northeast Waste Management Official’s Association (www.newmoa.org)

18 Mercury Containing Products
Relays and Tilt Switches Root Switch from Sump Pump Tilt Switch from Washing Machine Mercury Displacement Relay Mercury Wetted Relay Mercury Contact Relay Flame Sensor from Gas Range Source: Northeast Waste Management Official’s Association (www.newmoa.org)

19 Mercury Containing Products
Batteries – Standard Mercury Batteries, Alkaline Batteries Zinc Air Miniature Batteries Silver Oxide Button Cell Batteries Alkaline Manganese Oxide Button-Cell Not all thermostats will contain mercury. There are thermostats available that do not contain mercury. Mercury Thermostat Mercury Thermostat Mercury Switch inside Thermostat Source: Northeast Waste Management Official’s Association (www.newmoa.org)

20 Best Management Practices
Proper Disposal Spill Management BMPs for mercury containing products are proper disposal and spill management if the product breaks.

21 Proper Disposal Regulated by recycling and disposal requirements of the universal hazardous waste rules in the State of California Small business may qualify as a Conditionally Exempt Small Quantity Universal Waste Generator (CESQUWG). CESQUWGs can recycle their lamps at their local government sponsored Hazardous Waste Recycling and Disposal Program’s sites or they can contract with a hazardous water hauler to properly dispose of their hazardous waste. Small business generating less than 220 lbs. of hazardous waste (including fluorescent lamps and other mercury-containing wastes) and less than 2.2 lbs. of acutely hazardous waste within any month of a calendar year, may qualify as a Conditionally Exempt Small Quantity Universal Waste Generator (CESQUWG). (As an example, one box of 36 fluorescent lamps (four-foot long tubes) weighs about 24 lbs.) CESQUWGs are not subject to the same rules for training, accumulation, and packaging of their hazardous waste that the larger hazardous waste generators are. However, they do need to follow the recycling and disposal requirements of the universal hazardous waste rules of the State of California. CESQUWGs can recycle their lamps at their local government sponsored Hazardous Waste Recycling and Disposal Program’s recycling sites or they can contract with a hazardous water hauler to properly dispose of their hazardous waste.

22 Spill Management Never touch mercury with bare hands
Never use vacuum cleaners or brooms to clean up mercury spills Use cardboard pieces, a squeegee, or an eyedropper to gather and draw up the mercury Place the mercury and the items used to clean up the spill in a bag and dispose off as hazardous waste. Spill Management BMPs include (Permittees may want to include BMPs from their own materials): Never touch mercury with bare hands Never use vacuum cleaners or brooms to clean up mercury spills Use cardboard pieces, a squeegee, or an eyedropper to gather and draw up the mercury Place the mercury and the items used to clean up the spill in a bag and dispose off as hazardous waste.

23 Pollutant of Concern PCBs

24 PCBs Synthetic chemicals
Manufacture of PCBs was stopped in the U.S. in 1977 because of evidence they build up in the environment and can cause harmful health effects Regulated under the Toxic Substances Control Act (TSCA) Polychlorinated Biphenyls, or PCBs, are synthetic chemicals. Manufacture of PCBs was stopped in the U.S. in 1977 because of evidence they build up in the environment and can cause harmful health effects. PCBs degrade slowly and are still found in the environment – and storm drain systems are a big source of PCBs to the Bay. PCBs are regulated under the Toxic Substances Control Act (TSCA).

25 TSCA Regulations Designed to ban the manufacture of PCBs and ensure the proper disposal of PCBs and PCB equipment, while minimizing the risk posed by the storage, use, and handling of the substance. The TSCA regulations were designed to ban the manufacture of PCBs and ensure the proper disposal of PCBs and PCB containing equipment, while minimizing the risk posed by the storage, use, and handling of the substance.

26 TSCA Regulations Include numerous exceptions and authorized activities
Allowed uses of PCBs include servicing of PCBs in various PCB Equipment, such as transformers, capacitors, natural gas pipelines, and hydraulic systems The TSCA regulations included exceptions and authorized certain activities. The regulations allowed uses of PCBs including servicing of PCBs in various PCB Equipment, such as transformers, capacitors, natural gas pipelines, and hydraulic systems. There is still equipment today that contain PCBs.

27 TSCA Regulations Owners of PCB Transformers must register transformers with EPA Requirements for marking, storage, record keeping and disposal of PBC containing equipment While the TSCA regulations allowed certain uses, the owners of PCB Transformers must register transformers with EPA. The EPA includes these facilities in the Transformer Registration Database. (Permittees should add specific facilities in their municipalities that are registered. This information is provided in the transmittal memo and guidance manual.) There are also TSCA requirements for marking, storage, record keeping and disposal of PBC containing equipment.

28 Provision C.12.a Develop training materials
Train municipal building inspectors to identify PCBs or PCB containing equipment Integrate PCB inspections into existing inspections Reporting requirements The US EPA approved the Water Board’s total maximum daily load (TMDL) for PCBs in San Francisco Bay in March The MRP’s Provision C.12 PCBs Controls are to implement the urban stormwater runoff requirements of this TMDL. MRP Provision C.12.a requires Permittees to develop training materials and train municipal industrial inspectors to identify PCBs or PCB containing equipment. This training is being done to fulfill these two MRP requirements. Inspectors must document incidents when they identify PCBs or PCB containing equipment during inspections. Inspectors must refer the incident to the appropriate regulatory agency, as necessary. If the PCB equipment is already registered with the EPA and/or has the proper labeling, referring the facility to the appropriate regulatory agency is unnecessary.

29 Identification of PCB Containing Equipment
Equipment will be marked Look for labels on old equipment (1979 or earlier). The equipment should be marked as containing PCBs.

30 Identification of PCBs Containing Equipment
Look at Records Recordkeeping Requirements include PCB weights identification and numbers of items storage, transfer, and disposal dates identification of shippers and receivers Manufacturer’s label/PCB Fluid trade names Aroclor, Askarel, Eucarel, Pyranol, Dykanol, Clorphen, Clorinol, Chlorextol, Diaclor, Hyvol, Asbestol, Inerteen, Elemex, Saf-T-Kuhl, No-Flanol, Nepolin, EEC-18 The facility is required to maintain certain records which will provide you details of PCB equipment. Owners and operators of facilities with PCBs and PCB containing equipment in service or projected for disposal, commercial storage facilities of PCB waste, incineration facilities, chemical waste landfill facilities, high efficiency boiler facilities, importers, facilities generating PCBs in excluded manufacturing processes, and facilities that manufacture, import, process, distribute in commerce, or use chemicals containing inadvertently generated PCBs must comply with recordkeeping and reporting requirements. The recordkeeping requirements include PCB weights, identification and numbers of items; storage, transfer and disposal dates; and identification of shippers and receivers. If there are no records or labels look for certain types of equipment (manufactured before 1979) and ask about maintenance (e.g. if no records of maintenance may still contain original fluid that may have PCBs). Check for a manufacturer's label, which may give the date of manufacture and the trade name of the PCB's fluid. Some trade names that may refer to PCBs include Aroclor, Askarel, Eucarel, Pyranol, Dykanol, Clorphen, Clorinol, Chlorextol, Diaclor, Hyvol, Asbestol, Inerteen, Elemex, Saf-T-Kuhl, No-Flanol, Nepolin, EEC-18, and others. The following are types of equipment that may contain PCBs.

31 Transformers PCB Transformer Source: EPA
Transformers increase or decrease the voltage level of an electric current. Electrical transformers are often filled with a dielectric liquid that increases the resistance of the unit to arcing and acts as a heat transfer medium, helping to cool the coils. Today, most transformers are filled with mineral oil or silicone. The EPA defines PCB Transformers as "any transformer containing greater than 500 ppm PCBs. As stated previously, the owners of facilities that have a PCB transformer are required to register at the EPA’s Transformer Registration Database. PCB Transformers require service periodically and repair when out-of-order. Maintenance includes sampling fluid to test dielectric strength, topping off fluid (historically a source of PCB contamination), replacing gaskets, bushings, insulators, etc., which may involve partial draining of the unit, removing and filtering the dielectric liquid and refilling the unit, removing PCB liquid and refilling with replacement dielectric fluid and generating waste liquid, contaminated rags, equipment, etc., Any PCBs removed during any servicing activity must be captured and either reused as dielectric fluid or disposed of properly. Any wastes generated during maintenance should also be disposed of in accordance with the regulations. PCB Transformers can be re-classified by retrofilling them with dielectric fluid that has lower concentrations of PCB. PCB Transformer Source: EPA

32 Capacitors PCB Capacitor Source: EPA
Capacitors regulate the flow of electric current. PCBs were the dielectric fluid used in approximately 95 percent of U.S.-produced, liquid-impregnated capacitors manufactured prior to The regulations require that all capacitors be disposed of as a PCB Capacitor except when a specific capacitor is known not to contain PCBs based on a label or nameplate, manufacturers' literature, or chemical analysis. To assist in this determination, EPA regulations required all non-PCB, large low voltage capacitors, small capacitors, and fluorescent light ballasts manufactured between July 1, 1978, and July 1, 1998, to bear a "No PCBs" label. There are two general types of capacitors containing PCBs: (1) capacitors built into electrical equipment, such as fluorescent lights, televisions, and small motors, which are smaller in size; and (2) capacitors used as separate units in electrical power distribution systems, which are larger in size (see picture). PCB Capacitor Source: EPA 32

33 Hydraulic Systems Hydraulic Systems Source: EPA
Hydraulic systems are machines that operate by the force exerted by pressurized and confined liquid. Many steel manufacturing and die casting plants used PCBs in hydraulic systems to reduce fire hazards for machines that handled hot metals. These systems included hydraulic systems for metal dye casting equipment, trim presses, induction hardening machines, heat treating furnaces, forge furnaces, and forge presses. Hydraulic Systems Source: EPA 33

34 Fluorescent Light Ballasts
The PCBs are located in the light ballasts’ small capacitor or in the potting material, the insulating material inside the ballast. Since 1978, EPA has required manufacturers of fluorescent light ballasts to mark ballasts that do not contain PCBs with the statement “No PCBs.” Inspectors should assume that light ballasts contain PCBs in their small capacitors if they were manufactured before Please note that after July 1, 1998, fluorescent light ballast manufacturers are no longer required to mark fluorescent light ballasts with the statement “No PCBs.” Source: National Lamps and Components 34

35 Other Equipment Containing PCBs
Heat Transfer Systems Electric Motors Electromagnets Heat transfer systems use fluids of high heat capacity to remove unwanted heat or to transfer heat from one place to another within a system. They are commonly used to provide heat in chemical manufacturing where temperatures greater than that provided by steam are needed. Heat transfer systems in certain applications used PCBs as a heat transfer fluid. Heat transfer systems that contained PCB fluid were refilled with non-PCB fluid approximately 90 percent of the time. Despite this refilling, most systems contain residual PCBs. Leaks usually occur through pump motor seals. In the late 1960s and early 1970s, Reliance Electric for Joy Manufacturing Company manufactured electric motors that contained PCBs. Mining machine electric motors used on certain underground continuous loaders built by Joy contain PCBs as a coolant fluid in the large cutting head motors and traction motors. Previous versions of the regulations established a deadline of January 1, 1982, for phasing-out the use of these motors. The current regulations allow the use of PCB-containing mining equipment only under 50 ppm. Submersible well pump motors manufactured before 1979 may contain up to five ounces of PCB dielectric fluid in their capacitors. PCBs may leak out of these submersible well pump motors during normal wear-and-tear or when the pump suddenly fails due to lightening strikes or electrical failures or shorts. A list of manufacturer’s models and serial numbers of submersible pumps that may contain PCBs is available in the EPA PCB Inspection Manual (August 2004). Regulations prohibit servicing, including rebuilding, of PCB electromagnets with a PCB concentration of 500 ppm or greater that requires the removal of internal components. 35

36 Other Equipment These will be unmarked and possibly found in older buildings: Investment casting wax Carbonless copy paper Resins General sealants and coatings, including windshield sealant and silo sealant Lubricants, including bridge bearings and additives to transmission fluids Paint, including marine paint Electrical cable insulation (If electrical cable contains liquids or damp insulation, PCBs should be suspected.) Gaskets Roofing materials These products may possibly contain PCBs if found in older buildings, vehicles and boats. 36

37 Best Management Practices
Employee Awareness Spill Containment Provisions in Work Area Proper Storage Proper Disposal No Leaks Employees should be aware of PCB equipment labeling, storage, reporting, record keeping and spill control requirements. Lack of worker knowledge of and training may lead to the spread of contamination through insufficient protective clothing and equipment, improper handling techniques and improper disposal of defective PCB-containing and/or PCB-contaminated equipment. Poor housekeeping and improper storage can also lead to PCB spills. In addition, spills can occur in the following operations: maintenance operations, decontamination operations, transport operations, draining, refilling operations, contamination of waste oil and Disconnection/disassembly of railroad transformers Equipment should be stored according to TSCA regulations that cover the storage area (inside/ temporarily outside) and storage containers (properly marked, not leaking, etc.). Only EPA approved companies can dispose of PCBs containing equipment. Contaminated rags, filter media, and debris gathered during cleanup operations and contaminated soils need to be disposed of properly. 5) Some causes of leaks are: normal wear of equipment in service (e.g., valves, gaskets, and fittings), malfunctioning equipment , dismantling/reassembly of equipment, damaged equipment, cracked or damaged transformer bushings, containers used for storage and transport, equipment stored for disposal or reuse More detail is available in the U.S. EPA PCB Inspection Manual (August 2004). 37

38 INSPECTION FORMS Permittees should add their municipal specific inspection forms here. Show what information is collected on the forms that will be used to meet the MRP Annual Reporting requirements.

39 WRAP UP POC inspections to be integrated into existing inspection programs. Use Guidance Manual for quick reference Use Outreach Material for educating business operators Complete Inspection Forms The goal is to integrate pollutants of concern (copper, mercury and PCBs) into our existing commercial/industrial stormwater inspection program to meet the Municipal Regional Permit requirements. Inspectors can use the Guidance Manual as a quick reference while in the field. Use the available BMP outreach materials for education. Document inspections on the stormwater inspection forms. 39

40 Questions? Name and Contact Information of Trainer


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