Boatyard Wastewater

Treatment Guidelines

This 1996 document, produced by King County Water Pollution Control

Division, was originally published in 1991 by the Municipality of
Metropolitan Seattle (Metro.) The text remains substantially the same but
the name Metro has been changed to King County. For information or
reprints, contact the Industrial Waste Section of Water Pollution Control at
the address below.

King County Water Pollution Control

Industrial Waste Section
130 Nickerson Street, Suite 200
Seattle, WA 98109-1658

This document is available in accessible formats

upon request by calling (206) 684-2046 (voice) or
(206) 689-3413 (TDD.)

March 1996
 1. Introduction

In recent years, private citizens, businesses In 1992, the Washington State Department of
and government agencies have become Ecology (Ecology) will be issuing a general
increasingly aware of the need to preserve and NPDES (National Pollutant Discharge
protect area waterways. Puget Sound residents Elimination System) permit that will cover all
share an interest not only in maintaining the small boat-repair businesses in the state. This
beauty of the region but also in maintaining the permit will set limits on what can be discharged
economic vitality of a region that does business from a facility. It also will require businesses to
in shipping, transportation, fishing, shellfish implement pollution-control measures,
harvesting and recreational boating. These including treatment of pressure-washing
industries depend on both a healthy wastewater and its discharge to sanitary sewers
environment and the boat-repair industry to when possible.
remain economically viable.
This guide is designed to help boatyard
Special attention has been focused on the operators select wastewater discharge options
boat-repair industry because of its location and and wastewater treatment systems that will
past pollution-control practices. provide compliance with the general NPDES
Boatyards can protect and improve water permit and other permits that may be issued by
quality by preventing and controlling pollution. local municipalities for discharges to sanitary
The challenge for local regulators and the boat- sewers.
repair industry is to require and implement
control measures equitably and cost-effectively.

The Maritime Industrial Waste Project.

Much of the information maritime industry could be through in-kind contributions
contained in this document reduced. A major effort of from Metro and Ecology and
is provided by a study, the study was to pilot-test through private contributions
called the Maritime wastewater treatment by maritime businesses and
Industrial Waste Project, equipment at boatyards and equipment suppliers.
conducted by the shipyards. Testing was For more information about
Municipality of Metropolitan conducted in the Seattle area the Maritime Industrial Waste
Seattle (Metro). during summer 1991. Project, contact:
The project was Primary funding for the Industrial Wastb
established to characterize project was provided 130 Nickerson Street,
wastewater ~from the through a grant to Metro Suite 200
maritime industry and from the U.S. Environmental Seattle, WA 98109-l 658
identify potential treatment Protection Agency’s National 206-689-3000.
methods so that pollutant Estuary Program. Additional
discharges from the funding was contributed

1
 2. New Regulations Why, Who, What, How

@@:Are Maritime Businesses

&ing Regulated? The Boatyard General NPDES Permit will be
Federal and state laws require that the water available to all boat-repair facilities that
quality of all public waterways and water discharge wastewater to state waters. A boat-
bodies be protected. repair facility or boatyard is defined as a service
business engaged primarily in the repair of
Ecology, which is responsible for protecting small vessels, 65 feet or less in length. Common
the state’s public waters, recognizes that boatyard services include pressure-washing;
boatyards generate wastewater discharges that hull and topside painting; mechanical and
can cause pollution. Operations, such as structural repairs to boat engines, fuel systems
pressure-washing, are known to produce and sanitation systems; and other activities
wastewater contaminated with heavy metals, necessary to maintain a vessel. Moorage
such as copper, lead and zinc. Stormwater facilities are not covered by the boatyard
runoff from boatyards, where painting and general permit unless boat-repair activities are
sanding operations take place, also is conducted at the site.
recognized as a source of water pollution.
Ecology will provide notification of the
According to state and federal water availability of the general boatyard permit
pollution laws, businesses that discharge through direct mailings and notices in trade
wastewater from industrial operations must journals and newsletters and in newspapers.
have a wastewater discharge permit. Boatyard Boatyard owners or managers, however, must
operators may qualify for permit coverage ask Ecology for a permit application.
under the Boatyard General NPDES Permit,
which will be issued in spring 1992. General Y,j,?-_^. .,,,s,,-,

permits are less expensive and faster to obtain :Will Be Required?

than the individual NPDES permits that The Boatyard General NPDES Permit
shipyards are required to have. contains effluent limits and monitoring
requirements for the most common pollutants
discharged from boatyards. The level of
contaminants allowed in wastewater by the
general permit for discharge to state waters is
based on water-quality standards designed to
protect the marine habitat effectively. Because
small concentrations of pollutants are known to
affect marine plant and animal life adversely,
the level of pollutants allowed is very low.
Based on what is currently known about the
concentration of contaminants in pressure-
washing wastewater, it will be necessary to
treat the wastewater for the removal of
contaminants before discharging it to either
state waters or sanitary sewers.
The permit also requires that each facility
have an operating plan to prevent

3
contamination of stormwater. Best management and treating slightly contaminated wastewater.
practices (BMPs) must be incorporated into the Boatyards located in areas where there is no
plan. BMPs may include requirements for sanitary sewerage system may need to consider
chemical and waste storage, use of tarps for zero-discharge options rather than treating to
dust control, sweeping and spill-control the extremely low discharge limits for receiving
measures. waters.
Even though discharging pressure-washing
$J$& Are Sanitary Sewers wastewater to sanitary sewers allows higher
.^;L*,*.a&~**
Involved? contamination levels than discharging it to
receiving waters, pressure-washing wastewater
The boatyard general permit requires
still requires treatment. The following sections
boatyards to discharge pressure-washing
advise boatyards on how to obtain necessary
wastewater to sanitary sewers or meet
permits and how to treat wastewater to meet
extremely low limits for discharging it to
permit limits.
receiving waters. Many communities have
sewage treatment plants capable of accepting
 3. How to Select a Discharge Route and Location

There are several wastewater discharge

routes for boatyards. They include:
l Receiving waters (river, lake or ocean)
l Sanitary sewers
l Zero-discharge
- Recycling in a closed-loop system
- Evaporating the total waste stream
- Eliminating pressure-washing
l Removal by a waste disposal company.
Selecting the best discharge route is often a
process of elimination. The decision tree shown
in Figure 3-l outlines a logical approach to the
selection process. If two routes are being
considered, the costs and potential operation
problems for each route should be reviewed.
Not all discharge routes are equal. Table 3-l
evaluates the advantages, disadvantages and
treatment requirements associated with the
different discharge routes.

Hookup to
NO _ sanitary sewers YES
is available
Compare costs
and problems
associated. with
options below:

Discontinue Zero- Hold and Pretreat for

pressure- discharge dispose of

‘I
discharge to
washing (evaporate) wastewater sanitary sewers
to waste
disposal
company Depekding on
Compare costs volume of
and problems wastewater,
of option above compare costs
with option below: with option below:

Zero-discharge
j Flecee;z;-lter /

Figure 3-l: Discharge Route Decision Tree

5
 Table 3-l : Evaluation of Pressure-washing Wastewater Discharge Route
Discharge Route Treatment Requirements Advantages Disadvantages

Receiving waters High level - Requirestreatment for None- Useful only if other High capital cost. High
dissolved metals. Reverseosmosis, options are unavailable. operational cost.
ultrafiltration plus ion exchange,or Holding-tank capacity
distillation probably required. required. High
monitoring costs.

Sanitary sewers Moderate level - Requires removal of Moderate capital costs. Sanitary sewer permit
major portion of suspendedparticles. Low holding-tank capacity. required. Permit
Settling and filtration, chemical Moderate permit and monitoring and
flocculation and settling or filtration, monitoring costs. reporting required.
dissolved-air flotation, or ultrafiltration
required.

Zero-discharge High level - Requires removal of most No permit requirements High maintenance
(recirculation) particulates. Similar technology to for treatment system requirements. Potential
sanitary sewer discharge, plus final discharge. Water bacterial problems and
polish filtration and bacterial control, conservation. pressure-washer
required. degradation.

Zero-discharge High or moderate level, depending on No permit requirements High capital equipment
(evaporation) wastewater volume. Evaporationsystem for treatment system costs. High operational
required. discharge. Off-site waste costs.
disposal minimized.

Haul-awayby waste None. Low capital costs. Low High disposal costs.
disposal company Low maintenance.Low On-side storage
permit requirements. capacity required.

6
 4. How to Collect and Treat Pressure-washing Wastewater

The goal of wastewater collection is to

capture the wastewater as it is generated so it
can be treated and disposed of properly.
Wastewater collection involves both
containment and routing. Containment
prevents wastewater from flowing outside a
specified area, and routing directs wastewater
to a central sump or depression.
Designing and constructing a collection
system can be done before, and independent of,
selecting a discharge route or treatment system.
However, the future location of the treatment
system and the point of discharge, such as a
sewer connection or utility cover, must be kept
in mind.
The guidelines for collection-system design
described below are inclusive options that have
worked effectively in boatyards.

Cranes, Travel Lifts and Trailer Hauls

These haul-out types are able to move boats
to upland areas. Always conduct pressure-
washing over land never over water where the
wastewater can be collected.

Basic Equipment/Facility Requirements

l Designated wash area with water-

impervious surface or tarpaulin sloping to

drain or sump. Drains or sumps should
contain wastewater so it can be conveyed to
a holding tank or treatment system.
Wastewater should not be allowed to drain
to storm drains or open waters.
l Containment structures surrounding the
wash area, such as raised berms or sloped
drainage trenches. l Fixed or portable sump pump.

l Collection sump or depressed surface area. l Overhead cover, where feasible to prevent
rainwater from collecting during pressure-
l Stormwater diversion system to route washing, An overhead cover may be more
stormwater away from the treatment practical at yards where power vessels are
system when pressure-washing is not serviced than at yards where sailboats are
occurring. serviced.

7
Typical Designs l Portable set-up system. A portable set-up
l Fixed-pad. A collection design similar to collection system can use a heavy-duty
those used for truck pressure-washing tarpaulin to contain wash water. A typical
facilities is shown in Figure 4-l. design, based on a system developed at
Miller and.Miller Boatyard, is shown in
Figure 42.
Raised curb (berm) Concrete or smooth
surrounding wash area asphalt surface

Figure 4-1: Fixed-pad Collection System

Portable Collection System Heavy-duty

Raised
tarpaulin
(place on
smooth
hard
surface)

,-----------^----- \\
\\

DETAIL

Flexible
hose

[Note: Place pump at low side of

slope or push water to pump with
broom or squeegee.]

Figure 4-2: Portable Collection System

8
Marine Railways
Marine railways are fixed-position haul-outs
where washing usually occurs on a slope
running to the shoreline. To contain pressure-
washing wastewater properly, a boat must be
raised to solid ground above the water line.

Basic Equipment/Facility Requirements

l Designated wash area with water-
impervious surface sloping to drain or
sump.
l Containment structures, such as raised
berms or sloped drainage trenches.
l Collection sump.
l Stormwater diversion system to route
stormwater away from the collection
system when pressure-washing is not
occurring.
l Sump pump.
l Overhead cover, where feasible to prevent
Typical Designs
rainwater from being collected during l Diagonal-berm collection system. A design
pressure-washing. based on a collection system constructed at
Gig Harbor Marina is shown in Figure 4-3.

\ Low-tide ,
High-tide Raised
diagonal berms curb (berm)

Marine
1 SLOPE railway

‘[NOTE: Wastewater can be pumped from

sumps by a single diaphragm (or similar)
pump located above high-tide level.]

Figure 4-3: Diagonal Berm Collection System for Marine Railways

9
 l Trench collection system. A design based The contaminants in pressure-washing
on a collection system constructed at wastewater that cause water-quality problems
Suldan’s Boat Works is shown in Figure 4-4. are copper, lead and zinc. These metals have
been found at concentrations that exceed the
discharge limits for receiving waters and
No adequate collection system has been sanitary sewers. Arsenic, also a contaminant of
identified for over-the-water hoists. The lack of concern, has been found in very low
a fixed deck or land makes it difficult to concentrations.
construct or provide a collection system.
When anti-foulant coatings are present, hull- ~~~~ Wastewater
washing over the water or in the water whether Characteristics
by hand-washing or pressure-washing will l Eighty to 90 percent of the heavy metals
release pollutants into the water. copper, lead and zinc are contained in the
Boatyard operators should be aware that solid particles in pressure-washing
these pollutant discharges violate state and wastewater. The remaining concentration of
federal environmental laws and, if released, heavy metals is dissolved.
may result in fines and/or restrictions on . The greatest percentage of particles are
boatyard operations. small, less than 50 microns or four ten-
thousandths of an inch in diameter. These
~3&$&Contaminants Must Be particles resist rapid settling and tend to
Treated? plug simple surface filters, such as cartridge
or bag filters. The paint particles also tend
Pressure-washing wastewater is composed
to adhere to each other, causing the filter to
primarily of particles of marine growth, such as
algae and barnacles, and paint particles Plug*
removed during washing. Paint particles are the l In most cases, the level of turbidity, or
source of heavy metals in the wastewater. cloudiness, in pressure-washing

Low-tide High-tide Raised

collection trench collection trench curb (berm)

+ SLOPE

*[NOTE: Wastewater can be pumped from

trenches by a single diaphragm (or similar)
pump located above high-tide level.]

Figure 4-4: Trench Collection System for Marine Railways

10
 wastewater is a good indicator of the level l Organic material contributed by marine
of heavy-metal contamination. growth decays rapidly in wastewater,
particularly if it is kept warm and still.
l pH values range from 6 to 9, with an
These conditions produce bacterial growth
average of about pH 7, the neutral value.
and foul odors. Be aware that decay gases
These values, which measure acid or base
kept in a sealed tank can create high-
conditions in wastewater, are within
pressure conditions.
tolerable limits for discharges to sewers, but
may exceed the limits for discharges to How Do Wastewater Characteristics
receiving waters.
Compare to Discharge Limits?
l Oil and grease, unless spilled or released Table 4-1 compares average and high
from bilges, are not problems in pressure- concentrations of untreated wastewater to the
washing wastewater. Oil and oily water discharge limits for King County’s sewerage
should be separated from pressure-washing system and the limits for receiving waters
wastewater. If oil is present, take special currently proposed for the Boatyard General
treatment steps, such as skimming, to NPDES Permit.
remove it.
The comparisons lead to two main
l Toxic or hazardous organic compounds are conclusions:
not problem contaminants unless spills
from painting, bilges or fuel tanks are l Pressure-washing wastewater requires
allowed to mix with pressure-washing treatment for removing several
wastewater. contaminants before being discharged to
either sanitary sewers or receiving waters.

Table 4-l : Boatyard Pressure-washing Wastewater Contaminants and Regulatory Limits

Permit Limit Values
Untreated Untreated Sanitary Boatyard NPDES
Analytical Sample Sample Sewers Sanitary Receiving Waters [6]
Parameter Units (average) [l] (high) (Metro) Sewers Marine Fresh

PH PH 7.2 6.7 - 8.2 5.5 - 12.0 [3] VI [41

Turbidity ntu 469 1700 131 [31 VI [41

[l] Values are based on analysis of 18 samples. [4] No monitoring requirements, but limits will be based on water-quality criteria.
[2] Oil and grease not detected by visible inspections. [5] Tin regulated by restrictions on the application of Tributyltin paints.
[3] No limit set or known for this parameter. [6] Limit values based on 8/13/91 draft of the Boatyard General NPDES Permit.

11
 l A higher level of treatment is required to solid particles. Recirculating the wastewater
meet the limits for receiving waters than is over the filter surface removes the solid
required to meet the limits for sanitary particles from the filter surface continuously.
sewers. Ultrafiltration, although effective, requires
replacement of the expensive filters. Over time,
#f@&Treatment Methods Work? they become irreversibly plugged.
<d:&ro.i..
.~
The following methods, when used properly, Treatment methods necessary to meet limits
can produce treated discharges acceptable for for discharges to receiving waters, such as
sanitary sewers: reverse osmosis or ion exchange, have not been
tested specifically for pressure-washing
l Chemical treatment (flocculation) and
wastewater. If it is necessary to discharge to
settling
receiving waters, a boatyard should consult
l Filtration (cartridge, bag, multimedia and wastewater treatment resources listed in
precoat), if preceded with settling or, Section 9.
preferably, with chemical flocculation
‘fig-#w@ Treatment Systems
l Membrane filtration (ultrafiltration). ,2a;r;;;;,,,,.&~~&&,
Chemical treatment, as applied to pressure- A boatyard may choose between two basic
washing wastewater, is simply the addition of treatment systems: a commercially available
certain chemicals to the wastewater. This packaged unit or a yard-developed component
addition causes small solid particles to adhere system. The choice depends on the preference of
together to form larger particles that settle out the particular yard. However, consider these
or are filtered. Without the addition of guidelines:
chemicals, the small particles in pressure- l A yard-developed system is better suited to
washing wastewater take many days to settle, small wastewater volumes of roughly less
slowing the contaminant removal process. The than 100 gallons per job and occasional
small particles also tend to plug filters rapidly. pressure-washing. A boatyard doing its
Filtration removes suspended solids from own work with two to six employees may
wastewater by forcing the mixture through a be a good candidate for a yard-developed
medium, such as folded paper in a cartridge system. This system costs less than a
filter. Filtration can be effective, particularly at commercially available packaged unit but
yards where few boats are washed, if may require more hands-on labor to
wastewater settling is conducted before operate.
filtering. Exact times of settling depend on the l A commercially available packaged system
specific concentration and nature of the is better suited to a boatyard that produces
wastewater, but settling times in the range of 2 more than 100 gallons of wastewater per
to 12 hours or more may be necessary. job and pressure-washes boats regularly. A
Alternatively, if chemicals that flocculate the large boatyard or marina may fall into this
small particles are added, the’settling time is category. The system costs more than a
reduced to one-half hour to one hour, filtration yard-developed one but may not require as
is more effective and the filter does not plug so much labor to operate.
readily.
An effective yard-developed system is
Ultrafiltrationis a membrane filtration chemical flocculation and settling. Alum
process in which wastewater is forced under (aluminum sulfate), iron chloride and several
pressure through a porous membrane. The proprietary flocculants can flocculate
pores in the membrane are smaller than the wastewater solids. Alum and iron chloride are

12
widely available from chemical supply stores. collects all the wash water. If a tarpaulin is
With alum or iron chloride, wastewater used, it must be deployed for each job.
becomes acidic, so lime (calcium hydroxide)
must be added to adjust the pH of the solution. Treatment ProcessDescription
Adjusting pH requires simple measurement l Transfer pressure-washing wastewater
involving common pH paper found at from the collection area to the treatment
gardening or pool supply stores. vessel(s) by using a sump pump and hose.
Successful commercially available systems l Add about 0.07 ounces of alum per gallon
include: of wastewater. For example, 35 gallons of
Multimedia filter systems, which include a wastewater would need 2.5 ounces of alum.
settling chamber before filtration Chemical amounts may need to be adjusted
for the wastewater.
Ultrafiltration systems
l Mix the wastewater and alum for several
Precoat filtration systems minutes with a mechanical mixer at slow
Chemical treatment systems that flocculate speed or by hand with a paddle. Clumps of
the paint solids. particles, or floes, will appear.
See Sections 9 and 10 for information on l Add about 0.14 ounces of lime per gallon of
equipment suppliers. the resulting solution, and mix well for
several minutes. Use a dust mask to avoid
Three Systems That Work breathing the lime dust.
The three following examples of treatment l Check the pH of the wastewater with pH
systems may help give you an idea of how a paper. If the pH is less than 8, add more
typical treatment process is implemented. doses of lime in smaller quantities. If the
pH is higher than 8, do not add more lime.
System One Small Operations
l Allow the wastewater to settle until the
When cleaning a boat, a small boatyard
solution clears. This process usually takes
typically generates less than 100 gallons of
about one-half hour.
water. The wastewater can be treated easily by
using a batch chemical treatment system l Pump or drain the clear water to the
constructed at the boatyard. A batch chemical sanitary sewer connection, being careful not
system can be set up simply by purchasing 35- to disturb the settled sludge.
gallon garbage cans as treatment vessels and l Transfer the sludge to another barrel for
placing them within a bermed and covered further settling. Add sludge from other
treatment area. A larger cone-bottomed tank treatments to this barrel, and drain off clear
may be preferable for handling larger water when necessary.
wastewater volumes and removing settled
solids. The boatyard may use alum and lime or A flow diagram depicting this boatyard-
iron chloride and lime for flocculation and pH developed collection and treatment system is
control, or contact a treatment chemical supplier shown in Figure 4-5.
for advice. In the following example, alum will The estimated costs for a small yard-
be used. developed collection/treatment system are
shown below:
Collection System
Heavy-duty tarpaulin $500
The boat is washed over a bermed collection
system such as a concrete pad or tarpaulin, that Treatment barrels (3 @ $20 each) 60

13
 Bermtid and covered treatment area 500 Treatment ProcessDescription
Pump, hoses and fittings ,500 All treatment equipment is located in a
bermed area. The batch chemical treatment tank
$1,560 should have a conical bottom and valves to
decant water from above the sludge layer and
System Two Medium to Large Operations draw sludge from the bottom of the tank. A
A batch chemical treatment system is a second batch tank is useful to ensure that
suitable system for a larger boatyard that sufficient wastewater holding capacity is
produces more wastewater from 100 to 500 available for uninterrupted pressure-washing.
gallons per day and pressure-washes regularly. One tank can be treated while the other one
This system uses the same treatment method as fills. The process includes:
the one outlined above but is designed on a
larger scale. The system may be a pre- l Adding and rapidly mixing chemical
engineered system purchased from a supplier flocculants, such as alum and lime in
that also provides treatment chemicals or a System One, with a mechanical mixer.
system the boatyard assembles on-site. An l Slowing the mixing process until
example batch chemical treatment system is flocculation occurs, then shutting off the
depicted in the flow diagram in Figure 4-6. mixer and allowing solids to settle to the
bottom of the tank. Treated wastewater
CoZZectionSystem then can be discharged by gravity or
The boat is washed over a bermed collection pumping*
system, and all water is pumped to a treatment
l Removing sludge by a waste disposal
tank. Design criteria for collection systems are company, or dewatering it with a filter
outlined earlier in this chapter.
press before disposal.

Optional cartridge

Wastewater 1

Bermed collection area

/ I I \
Berm
(portable tarpaulin) Pump Optional holding
treatment barrel
barrel barrel

Figure 4-5: Flow Diagram of Example Treatment System for Small Boatyards

14
 Optional filtration equipment, such as System Three - Large Operations
cartridge, bag or multimedia filters, may be This system best serves a larger boatyard that
installed with this system as a polishing step to routinely pressure-washes boats. The difference
ensure that discharge limits are met. In some between this system and System Two is that it
cases, when the wastewater produced is very uses a commercially available packaged treat-
low in solids, a filter can be used to treat the ment system. Consult with treatment equip-
wastewater without first chemically treating it. ment suppliers to determine installation and
This approach is more practical when using operation details. An example of this system is
filtering equipment, such as a multimedia filter, depicted in a flow diagram in Figure 47.
which has a high loading capacity and can be
cleaned for reuse. Settling is always Consider having a settling or chemical
recommended before filtration. flocculation step before using any filtration
process in this system. Some packaged systems
The estimated costs for this collection and may have this process integrated into the
treatment system are shown below: system. The addition of an extra settling tank,
Bermed treatment area Site dependent even with this type of system, provides more
effective treatment.
Batch treatment tank $500-2,500
The estimated costs for this collection and
Multimedia filter $2,000-$10,000 treatment system are shown below:
Cartridge filter $100~$500 Settling/multimedia filtration
Bag filter $200~$1,000 (packaged system) $5,000-$30,000
Filter press $5,000-$10,000 Ultrafiltration $15,000-$30,000
Piping and electrical System dependent Precoat filtration $10,000-$20,000
Flocculation/settling -
l,OOO-gallon batch !§3,000-$5,000

Optional filtration -
use cartridge, bag or
multimedia filtration
(multimedia filtration
recommended for

To discharge
Collection c Sump
system

o waste dispos

s (0.5-3.0 cubic feet)

treatment tank

Sludge
to disposal

Figure 4-6: Flow Diagram of Example Treatment System for Medium-sized Boatyards

15

--
Collection

Potential packaged
treatment systems
Multimedia filtration
Ultrafiltration
Precoat filtration
Flocculation/settling
Sludge
to disposal

Figure 4-7: Flow Diagram of Example Treatment System for Large Boatyards

16
 Additional equipment and site-preparation such as air exposure, forced air and/or solar
costs are shown below: Bermed treatment area heating. Exposing a large surface area and
$2,000-$5,000 frequently turning the sludge will speed the
process. All sludge storage and drying
Holding /settling tank -
operations should take place in the area where
500-1,000 gallon $l,OOO-$2,000
it is contained.
Filter press $5,000~$10,000
Regulations governing sludge disposal
Piping and electrical System dependent
Federal and state laws govern the disposal of
The treatment process used is dependent on industrial solid wastes. Pressure-washing
the particular system selected. The equipment sludge may be defined either as hazardous or
supplier or consulting engineer will provide the nonhazardous, depending on the results from
boatyard with the necessary installation and laboratory tests. Several different tests may be
operating details. required by either Ecology or the local health
department to meet regulations governing
solid-waste disposal to landfills. The most
Sludge will be produced by any process used common test is a sludge leaching test called
to treat pressure-washing wastewater. Correct TCLP (Toxicity Characteristic Leaching
disposal of sludge requires knowledge of both Procedure). If the TCLP test produces
sludge dewatering and the regulations concentrations of metals above regulated limits,
governing the disposal process. the sludge is defined as hazardous. However,
before a waste sludge can be sent to a landfill,
Sludge Dewatering other tests may be required. Ecology may
There are two primary reasons for sludge require that a fish bioassay test also be
dewatering: rendering sludge acceptable for performed to determine if the sludge waste is
landfill disposal, and reducing the costs of hazardous. Contact both Ecology and the local
disposal by a waste disposal company. health department for information on sludge
testing and handling requirements.
A common method for dewatering sludge is
to press the water out of the sludge in a filter A boatyard may also choose to regard its
press. A filter press operates by pumping sludge as hazardous waste, whether tests
sludge under pressure into a compartment confirm this or not. By handling sludge as a
between two sealed plates. Water escapes hazardous waste, a boatyard may avoid the
through small channels in the plates. In a costs of testing and possibly dewatering the
Maritime Industrial Waste Project field test, a sludge if the sludge is hauled off wet. In
filter press dewatered shipyard sludge so it addition, by handling sludge as “worst case”
would pass the dryness test for disposal to a sludge, the boatyard can be more confident that
landfill. Commercial filter presses of the type the sludge is being disposed of in a more
tested range in price from $5,000 to $10,000. Not environmentally safe way than disposal to a
all sludge is dewatered effectively in filter municipal landfill. To get more%formation, see
presses. Before being purchased, equipment Section 9 under “Hazardous Waste/Sludge
should be tested on sludge actually produced at Disposal.”
the boatyard.

CI Sludge can also be dewatered by evaporation.

Commercial sludge dryers are available but are
I- generally designed for large-volume producers.
Consider devising alternative drying methods,
II-
17
I
TCLP Tests
Two TCLP tests were performed on shipyard
sludge produced from pressure-washing
treatment systems evaluated by the Maritime
Industrial Waste Project. In both cases, sludge
samples passed the TCLP test. These results
cannot predict the TCLP results for other
sludge, but they do indicate a high probability
that other pressure-washing sludge will pass
the TCLP test.

Disposal Options
Two basic sludge disposal options are
available:
Contracting with a waste disposal company
to haul away wet or dewatered sludge.
Contacting the local health department to
arrange for disposal at a landfill. A TCLP test
and sludge dewatering will be required. Other
tests also may be required.

18
 5. How to Obtain Discharge Permits

Boatyards located on or near the water are If a facility is able to discharge wastewater to
required to have an NPDES permit to cover a municipal sewerage system, Ecology requires
discharges of stormwater, bilge and ballast discharge to that sewerage system. In some
water, and pressure-washing or hydroblasting cases, the boatyard may have two discharge
wastewater. In Washington state, boatyards permits: the general NPDES permit issued by
may qualify to be covered by the boatyard Ecology and a discharge permit or
general permit. This general permit contains: authorization from the local municipality. As a
l Discharge limits general rule, limitations and conditions in
NPDES permits are more stringent than those in
l Monitoring requirements permits for discharging to sanitary sewers.
l Notification and reporting requirements
Boatyards not able to discharge to a
l Requirements for spill-control plans municipal sewerage system
l Requirements for chemical storage and A boatyard that is not able to discharge waste
waste disposal to a municipal sewerage system is required to
obtain the Boatyard General NPDES Permit.
l Requirements for BMPs.

Obtaining Permits
l To get a discharge permit, first contact the l To obtain permits or authorizations from
agency that issues the permit and request municipalities authorized to regulate
application materials. The application industrial dischargers, contact the one that
materials explain requirements, permit fees, serves you:
the permit process and the time frame for
King County (formerly Metro)
issuing the permit. You may request a copy
Seattle ............................. (206) 689-3000
of the Boatyard General NPDES Permit to
Bellingham ........................ (360) 676-6850
see what may be required.
Central Kitsap ................... (360) 876-7197
l To obtain the Boatyard General NPDES Cowlitz County ................ (360) 577-3127
Permit, contact Ecology’s regional office Everett ................................ (206) 2598819
covering your location: Lynnwood ......................... (206) 670-6662
Department of Ecology Olympia ............................. (360) 753-8428
Northwest Region ............ (206) 649-7000 Pierce County ................... (206) 565-3013
Bellevue Port Angeles ...................... (360) 457-0411
(Island, King, San Juan, Skagit, Tacoma ..................._..........(206) 591-2022
Snohomish and Whatcom counties) Vancouver ......................... (360) 696-8008
Department of Ecology
Southwest Region ............ (360) 753-2353 Phone numbers for other municipal sewerage
Olympia systems may be found on sewer bills or in the
(Olympia Peninsula, Pierce and phone book.
Thurston counties, and southwestern
Washington)

19
This permit covers all discharges to state The following municipalities in the Puget
waters, including stormwater, bilge and ballast Sound area have the authority to regulate
water, greywater and pressure-washing or industrial dischargers: King County,
hydroblasting wastewater. This permit is issued Bellingham, Central Kitsap, Everett, Olympia,
and enforced by Ecology. Pierce County, Port Angeles and Tacoma.
If a boatyard is located in an area where the
Boatyards with the option to discharge
local municipal sewerage system does not have
some or all wastes to a municipal
the authority to regulate the discharge of
sewerage system
industrial wastewater but does agree to accept
If a boatyard is located where the local the wastewater into its system, then the
municipal sewerage system has the authority to boatyard must obtain the Boatyard General
regulate industrial and commercial discharges NPDES Permit. In this case, the general permit
to its system, then the boatyard must obtain covers discharges to state waters and the
both the Boatyard General NPDES Permit for municipal sewerage system. The NPDES permit
discharges to receiving waters and a waste is issued and enforced by Ecology, but the
discharge permit or authorization from the local boatyard must have the approval of thelocal
municipality for discharges to the sewerage municipality to discharge.
system. The waste discharge permit or
authorization is issued and enforced by the
local municipality.

20
 6. How to Prepare a Treatment System Engineering Report

As part of the permit application process, a The results of the Maritime Industrial Waste
treatment system engineering report must be Project may be used to help prepare the report.
prepared for regulatory agency approval. In However, it must be demonstrated that the
some cases, the report must be completed and boatyard operation is similar to those covered
submitted with the permit application. In other in the study. Drawings and specifications from
cases, the permit is issued with a compliance standard equipment suppliers can be used to
schedule for submitting the report. meet this requirement. Verification that the
selected process and equipment are appropriate
The report documents the development of the
for your site is required. General guidelines for
boatyard wastewater treatment system. It
an engineering report are summarized below.
should be complete and detailed enough so that
Information is also available in Washington
a person familiar with wastewater treatment
State Code (WAC) 173-240-130.
can assess whether or not an adequate job was
done in selecting the process chemistry and An operation and maintenance manual must
equipment. The report should contain, at also be included in the report as a guide for
minimum, a concise summary of the using the treatment system. Equipment
characteristics of the wastewater, a description suppliers’ manuals can be used, but instructions
of the procedure used to select the treatment specific to the site should also be included.
process, a description of the treatment process
and a listing of spill-control provisions.

Items that should be included in the Engineering Report

l Type and quantity of control and/or accidental l Description of the treatment

wastewater generated. discharge prevention. process, including the
(Holding tanks and amount and kind of
l Site map, including the
treatment tanks must be chemicals used in the
location of the pretreatment
bermed to contain 110 treatment process.
system.
percent of the volume of the
l Discussion of the selected
l The location of wastewater largest tank.)
method of final sludge
sources at the site, the
l Verification that effluent disposal.
routing of wastewater and
from the proposed facility Schedule for final design
the treated wastewater l
will meet applicable permit
discharge point. and construction.
lirnitations for effluent.
l A flow diagram of the
l Basic design data and sizing
treatment process.
calculations of the
l Description of the physical pretreatment system
provisions for oil and components, such as
hazardous material spill pumps, tanks and mixers.

21
 7. Maintaining Compliance

Successful environmental protection and contact with stormwater. Typical source-control

permit compliance are not automatically BMPs for boatyards include use of tarpaulins,
guaranteed by selecting the correct hardware or roofing, drip pans, sweeping, covers and berms
implementing a BMP plan, which is outlined for storage of waste materials, and storage for
below. Success also requires an ongoing raw materials, such as paints, cleaners and
commitment to system maintenance and petroleum products. Treatment BMPs include
procedures review. Understanding a system on-site treatment before discharging to surface
and the intent of a procedure is the key to waters or a municipal sewerage system. An oil-
achieving success. water separator is an example of an on-site
treatment BMP.

BMPs refer to dozens of pollution-control @#@f$fRequired?

techniques. These methods rely heavily on Yes. Ecology requires BMPs as a condition of
business owners altering practices of operation waste discharge permits. If a boatyard fails to
and housekeeping to keep pollutants out of implement BMPs, it will be required to conduct
surface waters and groundwaters. frequent sampling to show that the yard is not
polluting. The expense of this sampling will
BMPs fall into two general groups: source-
usually demonstrate that BMPs must be
control and treatment. Source-control BMPs
implemented.
keep pollutants from coming into contact with
stormwater or receiving waters. Treatment Local shoreline management programs,
BMPs consist of treatment methods that remove municipal sewerage systems and air pollution
pollutants from the waste stream. control agencies can also require BMPs.
Incorporating BMPs into your operations will
Source-control BMPs are preferred because
facilitate compliance with a variety of
they are less expensive and, if effectively
regulations.
employed, prevent pollutants from coming into

a Implementing BMPs

a l Review current yard operations related to

contaminant control.
Call Ecology to obtain a draft of the
Several public agencies and business
associations have written BMPs specifically
for boatyards. Copies are available from the

a
l
following:
Boatyard General NPDES Permit and/or an
example of an individual shipyard NPDES Lake Union Association ..... (206) 284-2308
permit. Review the BMP sections. Puget Sound Shipbuilding
a l Get examples of other BMP packages from
maritime associations.
Association ...............I.......(206) 3236400
Northwest Marine
Trade Association ............ (206) 634-0911
a l

l
Develop BMI’s specific to your yard.
Start an employee awareness program.
Department of Ecology
Northwest Region ........... (206) 649-7000

I
a 23
gg&TEffective Are BMPs?
expensive, but it may be the only option for do-
.*I<:.-: ,:~.,,:.
it-yourself yards that are unable to implement
Source-control BMPs are effective if they are
source-control BMPs. Since some municipal
tailored to specific boatyards and incorporated
sewerage systems may accept contaminated
into routine repair activities. In NPDES permits,
stormwater from small areas, some yards may
the discharge limits, or the actual concentrations
devote a part of the yard for working on boat
of pollutants like copper and lead, for
bottoms, requesting that the stormwater in that
stormwater are extremely low. Considering that
area be discharged to the sanitary sewers.
the concentration of copper in antifouling paints
Source-control BMPs still may be required, but
can be as high as 40 percent, even small
they are less costly and more effective than a
particles of paint chips in stormwater can
treatment BMP.
exceed the limits. Source-control BMPs are
difficult to implement in large yards where boat Stormwater BMPs required in NPDES
owners are allowed to work on their own boats. permits are minimum requirements. To meet
the limits, a typical yard will have to go beyond
Treatment BMPs may be effective if they are
the minimum BMPs.
sized for the operation and maintained
frequently. Treating stormwater can be

24
 I
1
1
8. Compliance Checklist 1
1
1
The following checklist may help businesses 0 Size the treatment system, wastewater and 1
take all the essential steps needed to select sludge holding tank(s), and discharge piping 1
wastewater treatment systems that meet permit and pumps. 1
discharge limits and to develop appropriate
BMPs: 0 Prepare an engineering report and operation f
and maintenance manual for regulatory 1
0 Determine the yard’s best discharge route(s) agency review. 1
for was tewa ter. 1
•l Select and install the treatment system.
0 Determine what permits are required. 1
m Determine what BMPs for stormwater
0 Apply for permits. 1
contamination control are needed.
0 Install coIlection system(s) in 1
pressure- 0 Develop yard-specific BMPs and an 1
washing areas. awareness program for workers OYlessees. 1
0 Review wastewater characteristics and 0 Implement BMPs. 1
discharge limits. ii
0 Review engineering requirements for a 1
treatment system as specified in permit i2
applications. 1
ii
1
i2
1
1
1
1
1
1
1
r;
1
1
ii
1
i2
1
1
1
1
1
1
1
r;
1
1
25
1
f
1
 9. Where to Get Information

&@g#‘the Services of Consulting l Is the equipment being used currently, or

Engineers and Vendors has it been tested for its ability to treat
pressure-washing wastewater?
Many of the steps leading to the development
and installation of a wastewater treatment l Can you provide test results from or
system may be carried out by the boatyard or references for a system in operation?
by a consulting engineer or equipment vendor. l Are wastewater permit limits being met by
These steps include system design, equipment these operating systems, or do test results
specification and acquisition, site preparation, show that permit limits can be met?
equipment installation and system start-up.
l What waste contaminants - dissolved
A consulting engineer can assist the boatyard metals, solids, or oil and grease - does the
with any or all the steps. An equipment vendor equipment remove?
may be able to provide only some of the work.
l Is the equipment designed to allow for the
The following approach might be helpful in accumulation and removal of solids?
determining what kind of assistance is most
appropriate: l If wastewater is to remain in the system for
an extended period of time, does the
l Review this manual to determine the basic equipment provide for biological growth
design and equipment requirements for a control?
collection and treatment system suited to
the boatyard needs. l Can the equipment be pilot-tested on-site?
l Determine what resources and capabilities l Can the equipment be leased before
are available within the boatyard and what purchase?
outside assistance may be needed.
l Check with equipment suppliers to
determine the extent to which they can
provide design engineering or other
assistance. Permits and Regulations
l Sanitary sewers
l Ask consulting engineers for proposals For pretreatment permit and approval to
covering the scope of work desired. This
discharge to a municipal sewerage system,
manual may be given to consulting call:
engineers as a predesign or engineering
specifications document. industrial Waste
(Seattle, and King and south Snohomish
Questions for Equipment Vendors counties)
When contacting equipment vendors for (206) 689-3000
information about wastewater treatment Local publicly owned treatment works
systems, a boatyard should ask: (POTW) or sewer utility
l What is the treatment capacity, pollutant Seethe blue pages (government section) in
removal efficiency and cost? the phone book, under your city’s name,
sewer utility or water and sewer district.

27
l Storm sewers/natural waters/septic systems l Solid waste
For NPDES permit and approval to For information on disposal requirements
discharge to a storm drain, river, Puget for landfill, dumpster and garbage, call:
Sound, the ground or other natural Local health dqartment
waterways, call: See the blue pages (government section)
Department of Ecology in the phone book under your county’s
Stormwater Section name.
Northwest Regional Office l Fire regulations
(King, Kitsap, San Juan Island, Skagit, For information on proper storage areas
Snohomish and Whatcom counties) and conditions for combustible and
(206) 649-7062 hazardous materials, see Articles 79 and 80
Southwest Regional Office of the Uniform Fire Code, or call:
(Clallam, Clark, Cowlitz, Grays Harbor, Local fire department
Jefferson, Lewis, Mason, Pacific, Pierce, See the blue pages (government section)
Skamania, Thurston and Wahkiakum in the phone book under your city’s
counties) name.
(206) 753-2353
l Building and shoreline construction
Central Regional Office For information on building or shoreline
(Benton, Chelan, Douglas, Kittitas, permits, call:
Klickitat, Okanogan and Yakima
counties) Seattle Department of Construction and Land
(509) 575-2490 Use (DCLW
(Seattle area) (206) 684-8850
Eastern Regional Office
(Adams, Asotin, Columbia, Ferry, LocaI building department
Franklin, Garfield, Grant, Lincoln, Pend See the blue pages (government section)
Orielle, Spokane, Stevens, Walla Walla in the phone book under your city’s
and Whitman counties) name, “building department” or
(509) 456-2926. “construction department.”
. Emissions to the air
Wastewater Treatment
For air-emissions permit and approval for
l King Cbunty (formerly Metro)
evaporation processes, call:
For discharge requirements, local limits in
Puget Sound Air Pollution Control Agency the Seattle area and pretreatment
(206) 296-7330 equipment review, call:
Olympic Air Pollution Control Industrial Waste process engineer
(206) 586-0593 (206) 689-3007.
Local air pollution control agency l Vendors
See the blue pages (government section) For information on available equipment
in the phone book under your county’s and technologies, see:
name, “air pollution.”
Yellow pages under water pollution
control, water purification and filtration
equipment and water treatment
equipment.

28
 l Consultants l For management of wastes that are
To hire professional assistance, see: designated as hazardous, see:
YeZZowpages under consultants: Yellow pages under waste disposal:
engineering and consultants: hazardous
environmental. The booklet, Hazardous Waste: A
l Boatyards Management Guide For Local Businesses,
For practical needs, costs, maintenance and available from King County at (206)
service information, other businesses in 689-3050.
your industry are a valuable resource.
Contact: Best Management Practices
Your local business association l For copies of BMPs written for boatyards,
BusinessesZistedas participants in this call:
guidelines publication. Lake Union Association ....... (206) 284-2308
l Trade journals Puget Sound
Pollution Equipment News Shipbuilders Association ..... (206) 323-6400
l-800-245-3182 Northwest Marine
Pollution Engineering Yellow Pages Trade Association e............... (206) 634-0911
P.O. Box 178, Techny, IL 60082. Department of Ecology
l Business and trade associations
Northwest Region ............. (206) 649-7000

American Waterway Operators Other Resources

Boatyard Operators Group l For excess or byproduct materials of
potential value or use to other businesses,
Marine Business Coalition call:
Northwest Marine Trade Association Industrial Materi& Exchange (IMEX)
Puget Sound Shipbuilders Association. (206) 296-4899.
l For waste reduction and recycling
Hazardous Waste/Sludge Disposal
information, call:
l To determine if your waste is hazardous,
refer to Washington Administrative Code Department of Ecology
(WAC) 173-303, the hazardous waste l-800-RECYCLE
regulations for Washington state. For a Hazardous Substances Information Hotline
copy of the regulations or assistance in l-800-633-7585.
designating your waste, contact:
l For employee health and safety information
Department of Ecology and assistance with Worker Right-To-Know
l-800-633-7585. Material Safety Data Sheet’ program, call:
Washington State Department of Labor and
Industries
(206) 281-5447.

29
 10. Maritime Industrial Waste Project Participants

See Table 10-l for a list of maritime See Table 10-3 for a list of equipment
businesses that participated in the Maritime suppliers, a description of the systems pilot-
Industrial Waste Project. tested and the locations of the tests.
See Table 10-2 for a list of wastewater-
treatment equipment suppliers that participated
in the project.

Table 10-l: Maritime Industrial Waste Project - Maritime Business Participants

Name Address City Contact

Pilot Test - Shipyards
Todd Shipyard Corp. 1801 16th Ave. S.W. Seattle Al Rainsberger
United Marine Shipbuilding Inc. 1441 N. Northlake Way Seattle Gregg Bishop
Duwamish Shipyard inc. 5658 West Marginal Way S.W. Seattle Don Meberg
Foss Maritime 660 W. Ewing St. Seattle Kris Lunde
Marco Seattle Inc. 2300 W. Commodore Way Seattle George Nielson
Lake Union Drydock Co. 1515 Fait-view Ave. E. Seattle Gary Carkonen

Pilot Test - Boatyards

Fishermen’s Boat Shop Inc. 1016 14th St. Everett Tom Young
Miller and Miller Boatyard 626 W. Ewing St. Seattle Paul Miller
Port of Seattle, Shilshole 7001 Seaview Ave. N.W. Seattle Mark Knudsen
Suldan’s Boat Works Inc. 1341 S.W. State Highway 160 Port Orchard Greg Suldan
Seaview East/West 4701 Shilshole Ave. N.W. Seattle Phil Rise
West Bay Marine Center Inc. 2100 West Bay Dr. Olympia Eileen Tefft

Wastewater Characterization
Gig Harbor Marina 3117 Harborview Dr. Gig Harbor Walter Williamson
Kitsap Marina 1595 S.W. State Highway 160 Port Orchard On-in Nelson
Northwest Yacht Repair 2046 Westlake Ave. N. Seattle Mark M. Lindeman
Port of Port Townsend P.O. Box 1180 Port Townsend Andrea Fontenot
CSR 2401 N. Northlake Way Seattle Scott Anderson
Anacortes Yacht Service Inc. 2517 ‘T’ Ave. Anacortes Ernie Armstrong
University Boat Service Inc. 3137 Fairview Ave. E. Seattle Dewitt Whitman
Devlin Boat Co. 2424 Gravelly Beach Loop N.W. Olympia Sam Devlin

31
Table 10-2: Maritime Industrial Waste Project - Commercial Pilot-equipment Suppliers
Treatment
Company Equipment Address Contact Phone

Northwest Filter Co. Mixed-media filtration 345 Upland Dr. Mike Lynch (206) 5758700
Tukwila, WA 98188

IEECOHotsyoil-water 7622 146th St., Ct. E. Mike Firchow (206) 7355093

separator Puyallup, WA 98373

American RGFfiltration system 4401 Pacific Highway E. Steve Barker (206) 922-2626
Equipment Co. Fife, WA 98424
of Washington

Columbia Pacific & Landa filtration 7451 S.W. Coho Court, Suite 103 Jim McWhirter (503) 692-5123
Associates system Tualatin, OR 97062

Columbia Pacific & Koch ultrafiltration 7451 S.W. Coho Court, Suite 103 Jim McWhirter (503) 692-5123
Associates Tualatin, OR 97062

BlaceFiltronics Inc. Blace precoat 10914 N.E.39th St., Suite B-2 Tom Bewley (206) 254-9171
filtration Vancouver,WA 98662

Delta Pollution Delta flocculation 30540 SE. 84th St. Stuart Lindor (206) 222-4544
Control Inc. and filter press Preston, WA 98050

Environmental Beckart induced-air 460 S.W. Madison, Suite 1 Fred Hughes (800) 888-l 924
AssociatesInc. flotation Corvallis, OR 97333

Courtney & Nye Krofta dissolved-air P.O.Box 787 Leslie Grimm (206) 922-4744
flotation Milton, WA 98354

32
 Table 10-3: Maritime Industrial Waste Project -
Pilot-equipment and Maritime Businesses Selected for Field Tests
Equipment Supplier System Description Test Site
Commercial Systems Tested for
Pressure-Washing
Wastewater Treatment
Columbia Pacific & Associates Landa filtration system Seaview East Boatyard
Columbia Pacific & Associates Koch ultrafiltration United Marine Shipbuilding Inc.
Blace Filtronics Inc. Blace precoat filtration Todd Shipyard Corp.
Delta Pollution Control Inc. Delta flocculation and filter press Foss Maritime
Environmental Associates Inc. Beckart induced-air flotation Marco Seattle Inc.
Courtney & Nye Krofta dissolved-air flotation Duwamish Shipyard Inc.
Northwest Filter Co. Mixed-media filtration Suldan’s Boat Works Inc.
Northwest Filter Co. Mixed-media filtration Marco Seattle Inc.
American Equipment Co. RGF filtration system Fishermen’s Boat Shop Inc.
of Washington

Commercial System Tested for

Treatment of Oily Water
IEECO Hotsy oil-water separator Port of Seattle, Shilshole

Yard-Developed Systems
Tested for Pressure-Washing
Wastewater Treatment
Miller and Miller Boatyard Alum and lime flocculation Miller and Miller Boatyard
West Bay Marine Center Inc. Iron and lime flocculation West Bay Marine Center Inc.
Lake Union Drydock Co. Polymer flocculation Lake Union Drydock Co.

60264JB.PM6

33