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Engineering Report Alaskan Copper Facility Seattle, Washington

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Engineering Report Alaskan Copper Facility Seattle, Washington Engineering Report Alaskan Copper Facility Seattle, Washington May 15, 2015 Prepared for Alaskan Copper 130 2nd Avenue South Edmonds, WA 98020 (425) 778-0907 TABLE OF CONTENTS Page 1.0 INTRODUCTION 1-1 1.1 BACKGROUND 1-1 2.0 STORMWATER TREATMENT DESIGN IMPROVEMENTS 2-1 2.1 PREVIOUSLY INSTALLED STORMWATER TREATMENT 2-1 2.2 PLANNED STORMWATER TREATMENT IMPROVEMENTS 2-1 2.3 ADDITIONAL POTENTIAL SOURCE CONTROL IMPROVEMENTS 2-2 2.4 OUTFALL ANALYSIS 2-2 2.5 PROVISIONS FOR BYPASS 2-2 2.6 SAMPLING METHODOLOGY 2-2 2.7 OPERATION AND MAINTENANCE 2-3 2.7.1 Disposal of Used Filter Media 2-3 3.0 USE OF THIS REPORT 3-1 FIGURES Figure Title 1 Vicinity Map 2 Site Map 3 Stormwater Treatment South of Building 3300 TABLES Table Title 1 Facility Stormwater Analytical Data 2 Stormwater Treatment Testing Data for CB 330001 APPENDICES Appendix Title A CleanWay MetalZorb™ Product Information 5/15/15 P:\1198\001\FileRm\R\Engineering Reports\2015\AC Eng Rpt_05-15-15.docx LANDAU ASSOCIATES ii 1.0 INTRODUCTION This document presents an Engineering Report as part of a Level Three Corrective Action for the Alaskan Copper facility (Facility), located in Seattle, Washington, in accordance with the conditions of the National Pollutant Discharge Elimination System (NPDES) permit, specifically permit number WAR-000139 under the State of Washington’s Industrial Stormwater General Permit (Permit). This report presents the plans for stormwater treatment improvements with the goal to achieve benchmark concentrations of applicable parameters under the Permit. The Permit requires that water quality sampling of qualifying storm events be conducted once per quarter of each year. The Permit establishes benchmark concentrations for various parameters with increasing levels of response actions (i.e., Level One, Level Two, and Level Three) required based on the number of times the benchmarks are exceeded. Stormwater data collected in 2014 for copper triggered a Level 3 Corrective Action for evaluation and implementation of stormwater treatment by exceeding the benchmark value three or more quarters of the year. 1.1 BACKGROUND Alaskan Copper Works is located at 3200 6th Avenue South. Figure 1 shows the general vicinity of the Facility. Alaskan Copper performs dimensional steel and stainless steel pipe fabrication at the Facility. A site map that shows the Facility, its stormwater drainage features, and designated stormwater sampling location is presented on Figure 2. Some portions of the Facility drain to the City of Seattle’s combined sewer system. The stormwater discharge sampling location at the Facility, catch basin CB330001, is located south of Building 3300. Formerly, there was a second stormwater discharge sampling location at the facility at catch basin CB 331707, located south of former Building 3317 on the west side of 6th Avenue. However, Alaskan vacated that property in late 2014 and it is now occupied by another business. Stormwater analytical results at CB330001 since 2010 are presented in Table 1. Alaskan Copper had implemented stormwater treatment improvements in 2013. However, as can be seen from the data, the copper concentration was exceeded in all four quarters of 2014 and therefore stormwater treatment improvements are necessary. 5/15/15 P:\1198\001\FileRm\R\Engineering Reports\2015\AC Eng Rpt_05-15-15.docx LANDAU ASSOCIATES 1-1 2.0 STORMWATER TREATMENT DESIGN IMPROVEMENTS Past source evaluation work has been performed at the facility to identify sources of copper. The roofing materials of Building 3300 have not been identified to be significant sources of metals based on past roof downspout sampling and analysis. However, two small 55-gallon drum-size roof drain downspout “rain garden” treatment units were installed there in 2011 to provide extra help in trying to achieve the copper benchmark at CB330001. Catch basin media filtration treatment has also been employed at CB330001. 2.1 PREVIOUSLY INSTALLED STORMWATER TREATMENT For the Building 3300 and CB330001 drainage basin, oyster shell chips were first installed in September 22 through 26, 2011 in a modified catch basin structure in order to provide pH buffering of the stormwater, adsorb dissolved copper, and also to help entrain and settle suspended solids. Oyster shell is capable of buffering pH levels in stormwater to a less acidic level, which is less favorable to the solubility of metals and helps to promote adsorption of metals onto the calcium carbonate matrix of the shell. The catch basin was modified with a pipe tee installed at the outlet pipe, with the pipe below the tee providing a perforated underdrain to ensure stormwater flow through the shell media before discharging through the outlet. The pipe extending above the tee provides access to allow for sampling and provides a path for bypass of stormwater during extreme rainfall events. Limited sampling results of both the influent and effluent of the oyster shell catch basin (Table 2) indicate that it can achieve over 70% removal of copper from stormwater. Further stormwater treatment improvements were installed on April 29, 2013 at location CB330001. The improvements consisted of replacing the coarse oyster shell with more finely crushed oyster shell and also using MetalZorb™ product available from CleanWay Environmental Partners as a component of the media mix in the catch basin for further enhanced removal of copper. The MetalZorb media is a sponge structure coated with a metals adsorptive material. Manufacturer’s literature and an EPA technology description paper from when the product was known as the Forager Sponge are included in Appendix A. 2.2 PLANNED STORMWATER TREATMENT IMPROVEMENTS The MetalZorb media is quite a bit more expensive per cubic foot than the crushed oyster shell media, but it has a higher adsorptive capacity for metals such as copper and zinc compared with oyster shell. The product literature (Appendix A) suggested that the MetalZorb media is not fouled or otherwise negatively impacted by calcium ions. However, it is possible that the reason only minimal improvement 5/15/15 P:\1198\001\FileRm\R\Engineering Reports\2015\AC Eng Rpt_05-15-15.docx LANDAU ASSOCIATES 2-1 in treatment removal efficiency was observed after MetalZorb was combined with oyster shell in CB330001 (see Table 2) is that the oyster shell presented much higher calcium concentrations than were previously tested with the product, and the calcium ions possibly did adsorb onto the surface of the media and interfere with the adsorption capacity for copper. Therefore, the current plan is to change the catch basin adsorptive media to use of 100% MetalZorb media, with no use of oyster shell. The higher adsorptive capacity and faster reaction kinetics of the MetalZorb media will further reduce the copper concentration in stormwater and is expected to allow attainment of the benchmark for copper. The MetalZorb sponge media is a much lower density material than oyster shell and at times can be slightly buoyant. A top screen is already in place at CB330001 in order to make sure that the MetalZorb media does not float and get accidentally washed into the outlet overflow pipe tee. 2.3 ADDITIONAL POTENTIAL SOURCE CONTROL IMPROVEMENTS In addition to the planned stormwater treatment improvements, Alaskan copper is looking for ways to minimize the exterior storage and exposure of metal materials to stormwater that drains to surface water. One option that is currently being examined is to be able to eliminate all industrial operations and storage of materials south of Building 3300 and to consolidate that material in other portions of the facility without connection to surface water discharge. Alaskan copper may be able to make that transition within the next year. 2.4 OUTFALL ANALYSIS No new stormwater outfalls to surface waterbodies will be constructed for these planned stormwater treatment improvements. There will be no significant net change to the stormwater volume discharged or to the flow rate of discharge. 2.5 PROVISIONS FOR BYPASS The structurally modified oyster shell media catch basin (CB330001) has an overflow pipe to allow storm flow from extreme rainfall events to bypass and to prevent flooding. The roof downspout treatment units also have the ability to overflow stormwater from extreme rainfall events. 2.6 SAMPLING METHODOLOGY Quarterly stormwater sampling will continue to be conducted in accordance with methods outlined in the Facility’s Stormwater Pollution Prevention Plan (SWPPP). The designated stormwater sample collection location will remain CB330001. 5/15/15 P:\1198\001\FileRm\R\Engineering Reports\2015\AC Eng Rpt_05-15-15.docx LANDAU ASSOCIATES 2-2 2.7 OPERATION AND MAINTENANCE The operation and maintenance of stormwater treatment will consist of ongoing visual monitoring of storm drainage at the Facility. Monthly documentation of the condition of the CB330001 catch basin with MetalZorb treatment media and roof drain downspout treatment units is already part of the formal monthly facility inspections. The frequency of vactor truck servicing to remove the MetalZorb catch basin media at CB33001 will depend on the solids loading rate and whether a surface fabric filter is found to be effective as a pre- filter. It is anticipated that the MetalZorb media can provide good treatment for at least a 6-month period before needing to be replaced. Visual inspection observations and quarterly stormwater sampling results will help to determine the specific frequency of media replacement that will be required. 2.7.1 DISPOSAL OF USED FILTER MEDIA The stormwater filter media periodically needs to be replaced and the spent media disposed of. Spent filter media will be managed and disposed of per applicable laws and regulations. Given the known sources of copper and zinc at the facility, it is recommended that a sample of the spent filter media be analyzed for a standard suite of total metals for waste characterization (e.g., RCRA 8 metals), plus the additional analysis of total copper and zinc.
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