2009 ENVIRONMENTAL SEMINARBoat Bottom Pressure Washing

Requirements &

General Permit for the Discharge of Stormwater Associated with Industrial

Activity

Tuesday, August 18, 2009

Management of Vessel Pressure Washing Wastewater

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

Quick History of the Issue

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

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

*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

YOU DON’T HAVE TO SIGN THE CONSENT ORDER

If you don’t sign the consent order, you must:

1. stop discharging pressure wash wastewater to ground or surface water; or2. stop pressure washing boats…

BY SEPTEMBER 30, 2009

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

Implement 2002 Clean Marina BMPs for pressure washing

Submit copy of Exhibit A to Ed Finger @ CT DEP’s Water Permitting & Enforcement Division, to officially enter into Consent Order

Prepare & complete all plans and specifications for project

File all state and local permit applications (including COP)

Obtain all state and local permits, licenses & approvals

File Miscellaneous General Permit registration, if required

Submit Reporting & Certification Form to CT DEP describing timeline, certifying interim BMPs implemented & actions complete

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 TI

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Pad constructed of impervious material coated with a sealant

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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.

Process wastewater should not overflow or run off the pad at any time, nor should it accumulate and discharge to ground or surface water

Lockable valve, watertight cover or plug, or dedicated power source that can be secured is required for pumps used to divert stormwater

sump

Stormwater discharge

Discharge to tank or sanitary sewer

EXAMPLE ONLY-NOT FOR CONSTRUCTION

Post signs outlining proper operation

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CESweep and rinse pad prior to activating stormwater diversion

NOTE: 1)O&M for pad must be identified in SWPPP, included in weekly inspections, staff training, stormwater monitoring including sample location and procedures2)Inspection of pad must be included in Comprehensive Site Compliance Evaluation as part of SWPPP

Secure stormwater conveyance prior to pressure washing.

sump

EXAMPLE ONLY-NOT FOR CONSTRUCTION

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

Stormwater discharge

DEP Guidance on Managing Overspray

*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/lZinc 0.50 mg/l

Photo credit: Thomas MaGuire, Massachusetts Department of Environmental Protection

“process wastewater”

“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

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*