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2009 ENVIRONMENTAL SEMINAR

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2009 ENVIRONMENTAL SEMINAR Boat Bottom Pressure Washing Requirements & General Permit for the Discharge of Stormwater Associated with Industrial Activity – PowerPoint PPT presentation

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Title: 2009 ENVIRONMENTAL SEMINAR


1
2009 ENVIRONMENTAL SEMINAR
  • Boat Bottom Pressure Washing Requirements
  • General Permit for the Discharge of Stormwater
    Associated with Industrial Activity

Tuesday, August 18, 2009
2
Management of Vessel Pressure Washing Wastewater
3
Quick History of the Issue
  • Spring 2006 Discharge of pressure wash water to
    surface or ground water no longer allowed
  • December 31, 2008 Original deadline to cease
    discharge
  • May 2008 DEP publishes guidance for pressure
    wash water management
  • September 30, 2009 Deadline extension
  • March 2009 After much negotiation with DEP to
    extend Sept. deadline, CMTA sends letter to
    legislature and Consent Order is negotiated

4
DEP Guidance on Boat Bottom Pressure Washing (as
of May 2008)
  • Contain collect wastewater deflected from any
    boat surface during boat bottom pressure washing
    . Wastewater cannot be discharged to ground or
    surface waters
  • Handle wastewater as process wastewater.
    Process wastewater is not covered by the
    Stormwater General Permit and cannot be
    discharged to ground or surface waters

5
PW WASTEWATER MANAGEMENT OPTIONS
  • COLLECT, TREAT PIPE TO SANITARY SEWER
  • Treat water in compliance with General Permit for
    Miscellaneous Discharges of Sewer Compatible
    Wastewater (MISC General Permit) and
    regulations of municipal water pollution control
    authority
  • COLLECT, TREAT HAUL TO SANITARY SEWER
  • Transport water by the marina operator, or by a
    contract hauler licensed under CGS Section
    22a-454 for discharge to a municipal sewage
    treatment plant in compliance MISC GP local
    regulations
  • COLLECT HAUL TO INDUSTRIAL WASTEWATER TREATMENT
    FACILITY
  • Collect wastewater in a tank and transport by
    licensed waste hauler to licensed industrial
    wastewater treatment facility

6

Facilities must either cease discharge of
pressure wash waste water by September 30, 2009
or enter into Consent Order Agreement with CT DEP
to extend deadline to December 31, 2010
7
YOU DONT HAVE TO SIGN THE CONSENT ORDER
  • If you dont sign the consent order, you must
  • 1. stop discharging pressure wash wastewater
    to ground or surface water or
  • 2. stop pressure washing boats
  •  
  • BY SEPTEMBER 30, 2009

8
IF YOU DO SIGN THE CONSENT ORDER
  • If you do sign the Consent Order, you must
  • 1. Officially sign onto Consent Order by
    September 15, 2009 and
  • 2. abide by the Terms and Conditions of the
    agreement and complete all enforceable milestones
  •  
  • BY DECEMBER 31, 2010
  •  

9
7/31/09
Implement 2002 Clean Marina BMPs for pressure
washing
Submit copy of Exhibit A to Ed Finger _at_ CT DEPs
Water Permitting Enforcement Division, to
officially enter into Consent Order
9/15/09 430pm
9/30/09
Prepare complete all plans and specifications
for project
10/31/09
File all state and local permit applications
(including COP)
3/31/10
Obtain all state and local permits, licenses
approvals
TIMELINE FOR CONSENT ORDER
4/30/10
File Miscellaneous General Permit registration,
if required
Submit Reporting Certification Form to CT DEP
describing timeline, certifying interim BMPs
implemented actions complete
4/30/10
12/31/10
Cease all unpermitted discharges of pressure wash
wastewater
Submit Reporting Certification Form to CT DEP
certifying that all actions have been complete or
certifying that PW discharges have ceased
12/31/10
10
Pad constructed of impervious material coated
with a sealant
Process wastewater should not overflow or run off
the pad at any time, nor should it accumulate and
discharge to ground or surface water
Designed to minimize stormwater running on to the
pad
Lockable valve, watertight cover or plug, or
dedicated power source that can be secured is
required for pumps used to divert stormwater
DEP GUIDANCE ON PAD DESIGN
sump
Discharge to tank or sanitary sewer
NOTE 1) Pads constructed to allow stormwater to
overflow when not pressure washing are considered
a point source and subject to the conditions of
the Industrial Stormwater General Permit.
EXAMPLE ONLY-NOT FOR CONSTRUCTION
Stormwater discharge
11
Post signs outlining proper operation
Sweep and rinse pad prior to activating
stormwater diversion
Secure stormwater conveyance prior to pressure
washing.
Maintain equipment, including hoses, to prevent
discharges. Leaks from hoses and equipment are
considered process wastewater discharges.   Use a
minimal amount of pressure water
Transport resulting solid waste to a permitted
waste disposal facility
Discharge to tank or sanitary sewer
DEP GUIDANCE ON OPERATION MAINTENANCE
sump
  • NOTE
  • OM for pad must be identified in SWPPP, included
    in weekly inspections, staff training, stormwater
    monitoring including sample location and
    procedures
  • Inspection of pad must be included in
    Comprehensive Site Compliance Evaluation as part
    of SWPPP

Stormwater discharge
EXAMPLE ONLY-NOT FOR CONSTRUCTION
12
DEP Guidance on Managing Overspray
overspray the incidental spray discharged from
a pressure washing gun during boat bottom
pressure washing activities that does not come
into contact with any boat surface, including any
that may drift by air current away from its point
of origin
  • No need to contain overspray as long as water
    source is a potable water supply and no
    additional chemicals or pollutants are added
  • If chemicals are added (eg., treated recycled
    water source) , no collection necessary if the
    wastewater meets the target criteria for copper,
    lead and zinc as specified in the Stormwater GP.
    The discharge of recycled water from a pressure
    washing gun must not exceed the following
    concentrations   Copper 1.3 mg/l
  • Lead 0.04 mg/l
  • Zinc 0.50 mg/l

process wastewater
Photo credit Thomas MaGuire, Massachusetts
Department of Environmental Protection
13

Facilities that do not sign on to the Consent
Order will be subject to the full enforcement
authority of DEP as of September 30, 2009
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