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EPA, CZM, TIER II —– ?
ACRONYMS
(Used previous article)
- CZM - Coastal Zone Management
- DEP - Department of Environmental Protection
- EHS - Extremely Hazardous Substances
- EPA - Environmental Protection Agency
- EPCRA - Emergency Planning & Community Right to Know Reporting Act
- HW - Hazardous Waste
- MEMA - Mass. Emergency Management Agency
- NPDES - National Pollutant Discharge Elimination System
- O/O - Owner/Operator
- RCRA - Resource Conservation and Recovery Act
- SPCC - Spill Prevention Control and Countermeasures Planning
- SWPP - Storm Water Prevention Plan Permit
For a more detailed summary, contact Ray Gaffey (617) 545-2803, or Nathalie Grady (978)– 808-1408
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Confused by all the acronyms? (See sidebar). In an effort to help “demystify” the governments rules and regulations, Mass. Marine Trades and Cape Cod Marine Trades co-sponsored two workshops in January and February to provide an overview of the Federal Regional Marina Initiative announced by the EPA in October 2003. The following was prepared by Nathalie Grady, MMTA’s new Communications Director. Officials from the Environmental Protection Agency (EPA), Coastal Zone Management (CZM), and the Mass. Emergency Management Agency (MEMA) highlighted key subjects for attendees.
There are federal and state requirements for marinas to report the presence of Extremely Hazardous Substances (EHS), as mandated under the Emergency Planning and Community Right to Know reporting Act. (EPCRA). The purposes of EPCRA are to encourage compliance, voluntary discovery and prompt disclosures, expedite corrective action and prevent violations. Officials stressed that there are no penalties for reporting after the fact; EPA wants to “reward” small businesses for voluntary disclosures.
When making reports marina owners/operators (O/Os) must use the Audit Policy, which protects businesses that initiate reports of EHS. Any spills that enter water must be reported to the National Response Center and a call to your local Coast Guard is also recommended. Spills on land must be reported to Dept. of Environmental Protection(DEP) and Mass. Emergency Management Agency (MEMA).
Following a spill, small businesses have 180 days to file a report; large businesses (over 100 employees) have 60 days to do so, regardless of whether the EHS is on a boat at the marina or is present at the facility. O/Os that collect revenue cannot disclaim the reporting requirement.
EPA officials dicussed Spill Prevention, Control and Countermeasures Planning (SPCC) and stressed the applicability of SPCC is a question of capacity, not inventory. A marina with a tank capacity of 55 gallons or more must create an SPCC Plan; otherwise an exemption applies. However, it does not protect an O/O for knowingly failing to report a spill, which is a criminal offense.
SPCC plans must be available during working hours for inspection and O/Os must review their Plans every 5 years. Individual boats need not be included ,but if there is a spill from a boat, O/Os must report it. Plans must also provide facility diagrams and secondary containment procedures (unless primary containment is consistently tested). Staff that handles fuel must be trained to do so.
Robin Lacy (617)556-1022) of CZM noted that current guides are available for marinas to implement Best Practices and achieve regulatory compliance.
EPA and DEP officials discussed the applicability of the Resource Conservation and Recovery Act (RCRA) to marinas. RCRA addresses hazardous waste (HW) storage handling and disposal. O/Os are ultimately responsible for all generated waste streams, including any abandoned at their facilities. The goal for O/Os should be to identify HW as soon as it its generated, including those less obvious such as saturated rags and pads used to clean waste. Weekly inspections of waste containers are urged to identify leaks or deterioration and employees handling HW must be trained to do so.
EPA also discussed storm water requirements under the National Pollutant Discharge Elimination System (NPDES), which impacts marinas as storm water mixes with pressure washing and sanitary wastes. O/Os may file for Storm Water Prevention Plan Permits (SWPPP) through Thelma Murphy ( 617-918-1615) at EPS. The permits only apply to facility areas where maintenance occurs; if indoors and waste never mixes with storm water, an exemption may be secured.
Best Management Practices for Marinas include proper paint and solvent storage; prohibiting paint spraying on windy days; dustless sanders; proper signage; and drain plugs for drainage sinks, etc.. If you are using a consultant, it its important that he/she assures you he/she has filed a Notice of Intent for a SWPPP both with the Commonwealth and the EPA.
A presentation was also made by WasteCap who has a Shrink-wrap Recycling Program and provids a regional collection system for boatyards and marinas which was subsidized in 2003 by MMTA.
About 80 firms were represented at these workshops. Further seminars are planned with consultants familiar with the paperwork and requirements. The EPA contact would be Larry Wells (617) 918-1836.
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