EBI Consulting | Burlington, MA | (800) 786-2346
Environmental Management & Engineering Services
The experts at EBI Consulting bring innovative approaches to assisting with the requirements of the US EPA and various state and local agencies. Our services include:
- Pressure Wash Management Alternatives
- Storm Water Permitting & Planning (SWPP)
- Oil Spill Prevention Control & Countermeasures (SPCC) Planning
- Emergency Planning & Community Right to Know Act (EPCRA) Reporting
- OSHA Training
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POWERWASHING BOATS? ABSTAIN OR USE PROTECTION!
From the Desk Of….Jamy Buchanan Madeja, Esq.
The time has come. The U.S. Environmental Protection Agency [EPA] is poised to do targeted marina and boatyard enforcement in New England this upcoming season, with a particular focus on discharge of pressure wash water from power washing boats. DON'T BE THEIR TEST CASE FOR MASSACHUSETTS. The Clean Water Act considers pressure wash water to be an industrial wastewater discharge to either the waters of the United States or to groundwater, depending on where the wash water goes. As discussed at the recent MMTA Education Conference, there are five basic choices for handling pressure wash water legally and responsibly:
1/ A federal direct discharge permit ("NPDES" or "National Pollution Discharge Elimination System" permit, a major big deal to apply for and obtain);
2/ A state groundwater discharge permit (again, highly unlikely to be the best option);
3/ A permit to discharge to the local sewer system (watch for bilge discharges mixed with pressure wash water, because you'll have to meet the sewer system's local limits for pollutants such as grease, lead and other trace elements, which usually means pretreatment needed; this option can be the most cost-effective if the local sewer system can accommodate your industrial waste water);
4/ Installation of a closed-loop recycle system (no discharge at all, or off-site disposal after maximum recycling accomplished); or
5/ Installation of a holding tank for offsite disposal (often the most cost-effective option for smaller operations; price depends on cost of transport and disposal fees at appropriate treatment facility; representative sampling and analytical testing required for cost estimate).
All of the above options require a wastewater collection system on site. Given the limited space available to many marinas, planning now may be essential to your upcoming season. Keep in mind some local sewer system operators will be unfamiliar with your situation and may require longer application-and-approval processes than you would expect.
Two Massachusetts facilities with vastly different situations have recently installed pretreatment pressure wash water systems, using rare government subsidies to become pilot projects: Cape Ann Marina in Gloucester (Pre Treated to Local Sewer) and Arey's Pond in South Orleans (closed-loop recycling system). Whether your marina or boatyard is of their size and type or not, don't get caught without protection. If you plan to pressure wash next season, consult MMTA's web materials from the conference for details and consultant references, and get started now with whichever option makes the most sense for your size and type of discharge. If you can't afford to pass the cost of full compliance along to your pressure washing customers over time, it may be time to reconsider pressure washing at all. The U.S. EPA's fines can be $33,500 per day, per violation.
For more information, contact Jamy Buchanan Madeja, Esq., MMTA's legal counsel, at 617-227-8410 or jmadeja@buchananassociates.com. Two MMTA members presented helpful consulting and engineering services at the MMTA conference: Paul Richard of EBI Consulting (617-715-1825 or Prichard@ebiconsulting.com) and Fuss & O'Neill 1-800-286-2469 or Terry McCormack 508-880-0680 or TerryMCCormack@comcast.net. Presentations may be downloaded at MMTA's members-only section of http://www.boatma.com/
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