Advisory Council

April 5, 2009

Clean Water Act and Storm Water Control

The Federal Clean Water Act generally allows for the filing of a lawsuit by any party who claims to have been adversely affected by the discharge of another.

While the successful filing of a citizen suite requires many facts to be proved, opinions on what is legally required to sustain a successful suite may surprise you.

This is a case study of a shipyard that believed it was implementing best management practices and storm water controls, such that it was effectively controlling the operations (and discharges) at it’s facility.

This presentation is intended to provide an overview of the Federal Clean Water Act requirements for sustaining/defending an allegation of violation of the Act, and will compare and contrast some specific judicial findings for each of these requirements.

This presentation is intended to provide an overview of the outcome of a specific Citizen Suite and identify some of the main themes in the judicial review of allegations related to compliance with the Federal Clean Water Act.

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April 5, 2009

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Shipyard Environmental Issues Track

The Advisory Council is a sponsor of the Lydia Frenzel Conference Series.

The 2001 Shipyard Environmental Issues Track of the Southern States Annual Environmental Conference (“SSAEC”) consists of a series of papers and presentations prepared for, and given at the 11th Southern States Annual Environmental Conference in Boluxi, Mississippi from September 24 — 27, 2001.

Many shipyards throughout the United States are in various stages of “struggling” with federal and state stormwater management requirements.

While, not unique in this regard, the Shipyard industry sector presents many issues that make implementing an effective stormwater management program difficult.

These include the following: (1) Shipyards generally are located at, and/or perform industrial operations at the intersection of the three environmental media: air, land and water, (2) Shipyard operations are job-shop in nature, and (3) common Shipyard processes, such as blasting and painting, must move to that area of the yard where the work piece (typically, the ship) is located.

As a result, pollutants generated from Shipyard operations tend to be immediately accessible to the environment, and may change frequently in type, magnitude and location of generation/discharge.

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April 5, 2009

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Storm Water Waste

A Primary Mission of the Council is to promote effective means of surface preparation in the maintenance industry using water and water/abrasive blasting techniques.

The theme of the 2001 Shipyard Environmental Issues Track theme is “Managing Shipyard Stormwater Discharges.”

No actual permit is issued to the facility, but rather the facilities files the NOI for permit coverage with the appropriate regulatory authority and then maintains coverage by complying with the terms of the general permit which are found in the Federal Register or equivalent state regulations.

Accordingly, shipyards may not discharge with storm water wastewaters such as bilge and ballast water, sanitary wastes, pressure washwater, and cooling water originating from vessels.

The Federal Clean Water Act generally allows for the filing of a lawsuit by any party who claims to have been adversely affected by the discharge of another.

With that, most storm water discharges are considered point sources and therefore require coverage by a National Pollutant Discharge Elimination System (NPDES) permit.

40 CFR parts 100 thru 149 contain the USEPA’s Water Program regulatory statues.

Facilities located in these areas and currently covered under the MSGP-1995 must obtain permit coverage under the MSGP-2000.

Self-monitoring reports – EPA’s Multi-Sector General Permit (MSGP) for storm water discharges requires operators of industrial facilities to perform as many as three types of monitoring of their storm water outfalls: visual examination, analytical monitoring, and compliance monitoring.

The Ship and Boat Building or Repair Yards listed under Sector R of the EPA’s MSGP does not require any analytical and/or compliance monitoring.

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April 5, 2009

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Storm Water

A Primary Mission of the Council is to promote effective means of surface preparation in the maintenance industry using water and water/abrasive blasting techniques.

Under its plenary authority pursuant to the Federal Water Pollution Control Act (“FWPCA” a/k/a “the Clean Water Act” or “CWA”), as amended, the U.S. Environmental Protection Agency (“EPA”) has developed a comprehensive program to regulate the discharge of pollutants into waters of the United States.

To date, EPA has implemented that approach through promulgation of several permit programs — a baseline general permit, an industry multi-sector general permit, and two rounds of municipal permits.

EPA also is looking to control storm water discharges through a watershed approach under its Total Maximum Daily Load (“TMDL”) program as well as through facility-specific, National Pollutant Discharge Elimination System (“NPDES”) permits tailored to the operations and pollutants of individual facilities.

The Clean Water Act has been a great success in improving the quality of water bodies in the United States over the past three decades.

Future water programs will focus more on eliminating remaining sources of pollution and addressing water bodies that remain impaired.

These programs, such as TMDLs, are water quality-based and likely to result in more stringent storm water, as well as process wastewater, permits in the near future.

Along the way, the presentation will define key terms from the statute and regulations, explain EPA’s Clean Water Act authority to enforce the Storm Water Discharge Program requirements and outline the regulatory compliance options available to facilities including shipyards.

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April 5, 2009

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Continuous Improvement Evolution

A Primary Mission of the Council is to promote effective means of surface preparation in the maintenance industry using water and water/abrasive blasting techniques.

We will examine how this continual improvement evolution came about and what the change means to the marine construction industry in terms of waste minimization and pollution prevention.

We will look at the volumes of water produced by waterjetting compared to storm water run-off.

You have to make the decision whether this is just for the effluent water from the jetting or if it will include the storm water runoff also.

Let’s estimate conservatively that the contractor will run 2 UHP Waterjetting pumps for 16 hours non-stop.

One of the major costs involved in a treatment system is how low the discharge contaminate numbers are that must be met.

After determining how much water will be generated and what you plan to do with it after treatment, you can look at the treatment system.

The wastewater is drawn from the holding tank at the prescribed flow rate determined and sent to a retention tank with constant agitation.

For more difficult applications it typically would pass though a gravity sand filter to capture any extremely fine particles.

3. Design a treatment system that is big enough to treat the amount of waste water you will generate, and be sure its design will remove all contaminates you need to have removed for discharge.

It is possible to run a UHP WJ unit with vacuum recovery on only 50 gallons a day.

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April 5, 2009

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Various Application Requirements

A Primary Mission of the Council is to promote effective means of surface preparation in the maintenance industry using water and water/abrasive blasting techniques.

MSDS and manufacturer’s ASTM F 718 sheets, Shipbuilders and Marine Paints and Coating Product / Procedure Data Sheet for (Applicable QPL) Coating System Being Applied.

4.8.4 A dust collector is required during the abrasive blasting process, the dust collector shall run a slight negative pressure to contain dust generated during abrasive blasting in a zone.

1. From a man lift (JLG) prior to the assembly of staging.

2. After the staging has been assembled, prior to the installation of the containment bulkheads, flameretardant PVC fabric covering, plywood containment bulkheads or any other aspect of the containment is setup (see Figures 1 & 2).

The containment bulkhead for each zone shall be sealed sufficiently to contain abrasive blasting dust and grit within the zone during abrasive blasting.

During the process the containment bulkheads are moved from the initial installation location just enough to expose the surface under the containment bulkhead (footprint, see Figure 3).

4.15.1 Take control of well deck overheads paint zones per the Event Schedule and restrict entry to urgent cases only, as determined by the Ship Superintendent.

PHASE 4: Abrasive PHASE 3: Paint this blast & clean this zone zone IAW paint simultaneous to painting system being applied in Zone 4.

13.3 CHECKPOINT (Tack coat): Verify tack coat is applied IAW Table 631-11-1, IV (Cure/Post Cure).

Product Manufacturer Expiration Date Color Applied Product VOC Base Portion Batch!

Plural Airless Conventional Airless Temperature Setting At Heater Temperature At Tip Hardener Portion Batch!

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