Boats require a great deal of attention. They must be scraped, painted, and cleaned. Their engines need to be lubricated and otherwise tended. They need to be prepared to withstand winter. Each of these activities has the potential to introduce pollutants into the environment.
Sanding, blasting and pressure washing are meant to remove paint and marine growth. In the process, toxic heavy metals such as copper and tin may be released. If heavy metals find their way into the water, they may be consumed by bottom-dwelling creatures and passed up the food chain to fish, birds, and humans. Heavy metals that are not incorporated into living tissue will remain in the sediments where they will substantially increase the disposal cost of any dredged material.
Paints, solvents, thinners, and brush cleaners generally are toxic. If spilled, they may harm aquatic life and water quality. Additionally, the fumes — known as volatile organic compounds (VOCs) — released by some paints and solvents contribute to air pollution. Likewise, oil and grease from maintenance areas threaten aquatic life.
Many of the cleaning products available for use in boat shops are also toxic and many contain caustic or corrosive elements. They may also contain chlorine, phosphates, inorganic salts, and metals. Even nontoxic products can be harmful to wildlife. For example, detergents found in many boat-cleaning products will destroy the natural oils on fish gills, reducing their ability to take up oxygen.
This Unit outlines measures you can take to minimize the environmental impact of boat maintenance activities.
Best Management Practices and Legal Setting
This Unit includes three sections of best management practices, an overview of the legal setting, and a Unit Review. Best management practices cover designation and management of work areas, general maintenance practices, and chemical handling. The following list provides an outline of BMPs you will find within each section.
Section 1: Work Areas and Boat Hull Washing
- Identify wastewater discharges
- Designate work areas
- Know your floor drains
- Control sanding and blasting
- Minimize impacts of boat hull washing
- Conduct in-water maintenance wisely
Section 2: General Maintenance
- Repair and maintain engines with care
- Winterize safely
- Boat cleaning
- Minimize impacts of painting and coating operations
- Minimize impacts of anti-fouling paints
- Boat disposal
- Educate boaters about their responsibilities
- Store materials with care
- Handle solvents carefully
- Battery storage and disposal
- Freon recovery
Before reviewing the best management practices, please take a few moments to review the legal setting for petroleum control at marinas. This overview of federal laws and regulations aims to provide a framework for shared requirements. However, it is a starting point and not a complete reference; please consult your state officials for complete requirements. Also, see: State Laws page for your state.
Clean Air Act
The Clean Air Act (42 U.S.C. §7401 et seq. 1970) is the comprehensive federal law that regulates air emissions from stationary and mobile sources. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants.
Your state may require permits for operations using paints and solvents due to their impact on air quality. If you are painting, you will likely need air permits, especially for units such as spray booths. In addition, you may need air permits if you are doing abrasive blasting or sanding operations, or have storage tanks for chemicals or petroleum liquids. However, there are numerous operations and types of equipment exempted from air pollution permits. The Clean Air Act also prohibits venting chlorofluorocarbons (CFCs, trademarked as “Freon”) into the atmosphere.
Clean Water Act: National Pollutant Discharge Elimination System Permitting Program
The National Pollutant Discharge Elimination System Permitting Program (NPDES), authorized by the Clean Water Act (CWA), defines boat wash water as “industrial process water.” Wash water cannot be discharged without an NPDES permit and cannot be comingled with stormwater runoff. Federal regulations require an industry to apply for a stormwater permit if stormwater associated with industrial activity at the facility discharges into a separate storm sewer system or directly into surface water. A stormwater permit is not required if stormwater does not discharge from the facility site or is discharged into a sewer system which leads to a wastewater treatment plant. A discharge onto the ground or into groundwater or septic system requires a groundwater discharge permit or needs to meet exemption conditions.
Effective wash water management is important not only to protect the environment, but also to avoid potential fines and the negative publicity associated with violations. The U.S. EPA has delegated the authority to carry out CWA requirements to most states that have demonstrated capacity and therefore state NPDES permits are issued instead; see your State Laws page for details (e.g., Mobile Power Washing and Environmental Regulations, General Permit for Wastewater from the Outside Washing of Vehicles, Equipment and Other Objects).
For a summary table of boat wash water regulations for the Great Lakes states, see archive materials at Boat Wash Water Management: Options for Great Lakes Marinas (Green Marina Project, Sea Grant). State permits are periodically updated or revised and vary somewhat from state to state, but all states prohibit discharges that would violate state water quality standards. Facilities are notified if the general permit requirements change.
Coastal Nonpoint Pollution Program
Section 6217 of the Coastal Zone Act Reauthorization Amendments of 1990 (CZARA) requires coastal states (including Great Lakes states) with approved coastal zone management programs to address nonpoint pollution impacting or threatening coastal waters. States must submit Coastal Nonpoint Pollution Control Programs for approval to both the U.S. EPA and the National Oceanic and Atmospheric Administration (NOAA). CZARA requires EPA, in consultation with NOAA and other federal agencies, to publish guidance specifying “management measures” to restore and protect coastal waters from specific categories of nonpoint source pollution. EPA has done so in a document entitled “Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters,” which includes a chapter on Marinas and Recreational Boating (Chapter 5). State Coastal Nonpoint Pollution Control Programs must provide for implementation of these measures or alternative management measures in conformity with these measures in the coastal management area generally.
If storing certain chemicals, operators must adhere to U.S. Department of Transportation standards for protecting against the risks to life and property inherent in the transportation of hazardous materials. Approved containers will carry specification markings (e.g., DOT 4B240ET) in an unobstructed area.