Section 1: Work Areas and Boat Hull Washing
Many Clean Marina best management practices are based on the federal Coastal Zone Act Reauthorization Amendments of 1990 (CZARA), which provide guidance for developing State and Territorial Coastal Nonpoint Pollution Control Programs.
Recommended management activities include putting into place effective stormwater runoff control strategies such as the use of pollution prevention activities and the proper design of hull maintenance areas. In the Stormwater Management Unit you learned the importance of “source control” in preventing pollutants from entering waterways. In this section, you will read a variety of best management practices that control sources of pollution.
For further detail, see: Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters, Chapter 5 (EPA).
Note: These are not regulations, but guidelines.
By the end of this section, you should be able to:
- Explain why it is important to identify and manage all wastewater produced at your facility.
- Designate work areas and adopt a variety of job-specific protocols to implement best management practices.
- Be familiar with options to minimize impacts of boat hull maintenance (e.g., sanding, blasting, pressure wash water management).
- Prepare to implement other restrictions if maintenance work is not strictly limited to the work areas (i.e., if in-water maintenance is allowed).
Best Management Practices
- 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
Identify Wastewater Discharges
A marina may generate process-related wastewater from equipment cleaning, boat washing, paint spray booths, or other sources. If you discharge wastewater directly to waters of the state, you will need a National Pollutant Discharge Elimination System Permitting Program (NPDES) permit for this activity (e.g., vehicle washing discharge permit). Wastes directed to a local wastewater treatment plant through a sanitary sewer may also be regulated. A large plant may be able to handle the wastewater from your business, however, even large wastewater treatment plants are not generally designed to handle industrial wastes like chemicals, metals, oils, etc. Because of this, the treatment plant may require you to conduct “pretreatment” (e.g., removal of metals, oil or grease, etc.) before discharging your wastewater to them. If you want to discharge process-related wastewater to a local wastewater treatment plant, you need to discuss these activities with the treatment plant manager.
Specific state regulations on managing such wastewater vary widely. See your State Laws page for more information.
- Identify all your process-related wastewater discharges.
- Be sure that you have obtained an NPDES permit and/or permission from the wastewater treatment plant for all of your discharges.
Designate Work Areas
One of the easiest ways to control waste and runoff pollution is to restrict the area where maintenance activities may be performed.
- Perform maintenance work in a designated work area that is designed to contain waste materials. Perform all major maintenance, such as stripping, fiberglass repair, and spray painting, in designated areas and as far away from the water as possible. Prohibit extensive maintenance or repair work outside of the designated maintenance areas.
Site selection and design for maintenance area:
- Locate the maintenance area as far from shore as is practical — ideally this is upland of a 100-foot shoreline buffer zone.
- Locate boat maintenance areas indoors or on an impervious surface (e.g., asphalt or cement where the debris can be collected easily). Sheltering the area from rain will prevent stormwater from carrying debris into surface waters.
- If asphalt or cement is not practical, perform work over filter fabric, canvas, or plastic tarps. Provide tarps to patrons conducting hull maintenance outside of designated area. Filter fabric will retain paint chips and other debris yet — unlike plastic, or to a lesser extent, canvas — will allow water to pass through. Tarps may potentially be reused.
- Use vegetative or structural controls cited in the Stormwater Management Unit to treat stormwater runoff.
Operations at maintenance area:
- Clearly mark the work area with signage or identify where maintenance can be performed in the marina rules. Signs can identify the area, such as: “Maintenance Area for Stripping, Fiberglass Repair, and Spray Painting” or describe best management practices that boat owners and contractors must follow, such as: “Use Tarps to Collect Debris.”
- Regularly collect all maintenance debris and dispose of it properly. Clean work areas after completing each operation or at the end of the day, whichever comes first. Remove debris from sanding, paint chips, fiberglass, as well as other trash. Determine if the collected debris is hazardous or non-hazardous waste and provide proper disposal; for help, see Waste Management and Recycling Unit. If it is non-hazardous and does not contain free liquids, take it to a municipal solid waste landfill or dispose of it in a dumpster. Check with your state for exemptions and specific requirements.
- Establish a schedule for inspecting and cleaning stormwater systems. Remove paint chips, dust, sediment, and other debris. Clean oil/water grit separators.
- Develop procedures for managing requests to use the workspace, to move boats to and from the site, and to ensure the use of best management practices.
Know your Floor Drains
Floor drains are found at many small businesses. A common floor drain system can include a concrete trench that runs down the center of a shop floor. The trench is designed to capture water, cleaners, oil, dirt, or other materials. Some shops have small rectangular or round floor drains connected to underground piping. Some floor drains are necessary for day-to-day operations. Others are used for emergency purposes only. Do you know where the floor drains in your business go? Are you discharging wastewater or other fluids into your floor drains?
- Check all of your floor drains and make sure you know where they drain.
- Prohibit the practice of hosing down the shop floor to minimize potential for contaminated runoff. Use dry cleanup methods.
- DO NOT put other fluids like oil, solvents, paints, or chemicals into a floor drain. Drains should not be used to direct industrial wastewater to septic systems or onto the ground. If the drain discharges to a local wastewater treatment plant, ensure the plant manager is made aware. You may be required to conduct treatment on the wastewater before discharging it. You may also need to get a permit for the discharge.
- If you have floor drains at your company that you are not using, have them capped or plugged.
- Install an emergency shut-off on the drainpipes to prevent accidental spills from entering the sewer.
Control Sanding and Blasting
Sanding dust may include a variety of toxic or otherwise harmful materials. The following strategies ensure that dust does not fall onto the ground, into the water or become airborne.
- Prohibit sanding or blasting work of any sort carried out by individual boat owners or their contractors unless it is done inside one of the designated shops or a vacuum sander is used and the residue properly disposed of.
- Rent or loan vacuum sanders to tenants and contractors. Vacuum sanders and grinders collect dust as soon as it is created. Vacuum sanders allow workers to sand a hull more quickly than with conventional sanders. Additionally, because paint is collected as it is removed from the hull, health risks to workers are reduced.
- Restrict or prohibit sanding on the water to the greatest extent possible. When sanding on the water is unavoidable, require use of a vacuum sander to keep dust out of the water. Use a damp cloth to wipe off small amounts of sanding dust.
- Prohibit uncontained abrasive (sand) blasting at your facility. Conduct blasting in the designated maintenance area, within a structure or under a plastic tarp enclosure. Do not allow debris to escape from the enclosure.
- If tarp enclosures are used, avoid blasting on windy days. Because tarps are not rigid, they do not eliminate wind flow through the blasting area, so they allow the wind to carry blasting material and residue into surface waters.
- Investigate alternatives to traditional media blasting. Hydroblasting and mechanical peeling essentially eliminate air quality problems. However, debris must still be collected — consider using a filter cloth ground cover.
- Avoid dust entirely by using a stripper that allows the paint to be peeled off. These products are applied like large bandages, allowed to set, and then stripped off. When the strips are removed, the paint is lifted from the hull. Dust and toxic fumes are eliminated.
- Invest in a closed, plastic medium blast (PMB) system. These systems blast with small plastic bits. Once the blasting is completed, the spent material and the paint chips are vacuumed into a machine that separates the plastic from the paint dust. The plastic is then cleaned and may be reused. The paint dust is collected for disposal. A 50-foot boat will produce about a gallon of paint dust; substantially less than the many barrels full of sand and paint that must be disposed of with traditional media blasting methods.
- Recycle used blast media. Investigate companies that recycle used blast media into new media or other products.
Minimize Impacts of Boat Hull Washing
Preparing a vessel for painting can generate paint chips, dust, and particles that may contain metals such as copper, zinc, and lead. Although some of these metals are relatively harmless on land, improper handling can allow them to get into the water. Even at very low levels, these metals can be toxic to aquatic life. Material washed into the water from hull maintenance areas can also contaminate sediments (sand and mud) in the marina basin, posing problems for dredging and the disposal of dredged material. Allowing pollutants to seep into the ground can eventually contaminate the site itself, posing problems if the marina is ever sold.
Any discharge to surface water from a point source requires authorization by an NPDES permit; a discharge onto the ground or into groundwater or septic system requires a groundwater discharge permit or needs to meet exemption conditions. Collection and treatment of wash water is an evolving issue in many states. Work with your state to ensure you are taking the necessary measures to adhere to regulatory requirements.
- Check with your state for rules on boat wash water discharge.
- Limit boat-washing activities to a designated boat hull maintenance area.
- Install infrastructural improvements to power washing area, including filtration of particles, and/or recycling the wash water. The area should minimize pollutant spread by containing all waste and wastewater. Surround an impervious maintenance area with a berm or retaining wall to contain any solids or liquids. Wash water disposal options include permitted discharge, recycling, hauling, or discharge to sanitary sewer.
- If collecting and treating wastewater is not feasible, wash boats on a permeable surface such as gravel or on a lawn as far away from the waterway or storm drain as possible. This will allow the wastewater to infiltrate into the ground. Make sure, however, that there is no drinking water well nearby. Place filter fabric over the permeable surface to collect solids. Dispose of solids in an appropriate manner. If washing over an impervious surface, use hay bales, filter fabric or compost socks to absorb and filter wash water.
- Cover maintenance area with tarp when not in use to prevent rainwater from entering the area.
- When working, place a screen or filter fabric over storm drain grates to collect paint chips and other debris.
- When pressure washing ablative anti-fouling paint, use the least amount of pressure necessary to remove the growth but leave the paint intact. Where practical, use a regular garden type hose and a soft cloth, but remember if wastewater is directed toward the surface water, a permit is still required.
Conduct In-water Maintenance Wisely
Always default to conducting maintenance on dry land, where it is easier to control, contain, and mitigate impacts. No debris or chemical wastes should be allowed to fall into the water. If you must conduct maintenance in the water, follow these recommendations:
- Keep containers of cleaning and maintenance products closed.
- Restrict or prohibit sanding on the water. When it is absolutely necessary to sand on the water, require use of vacuum sanders to prevent dust from falling into the water. Do not sand in a heavy breeze.
- Plug scuppers to contain dust and debris.
- Restrict or prohibit spray painting on the water.
- Discourage underwater hull cleaning in your facility. Given the concentration of boats, underwater cleaning is dangerous to the divers performing the work and the heavy metals that are released are harmful to aquatic life. Insurance to cover divers is also expensive.
- Offer incentives, like reduced mid-season haul-out rates for boaters. Contaminants from hull maintenance are more easily contained on land.