Department of Ecology Opens Comment Period for Revised NPDES General Permit for Boatyards
Print PDFJune 2, 2005
On May 18, the Washington State Department of Ecology (Ecology) issued a proposed revised NPDES general permit for boatyards. The general permit provides coverage for boatyard industries in Washington State that discharge stormwater and wastewater from their facilities. The revised general permit includes: an imposition of water quality benchmarks; modification of the monitoring requirements; development of a Stormwater Pollution Prevention Plan (SWPPP); and the requirement of vacuum sanding as a mandatory best management practice (BMP).
The Federal Clean Water Act established several mechanisms for achieving water quality goals — one of which is permitting under the National Pollutant Discharge Elimination System (NPDES permits) — which are administered by the Environmental Protection Agency (EPA). The EPA delegated the responsibility to administer the program to Ecology. Ecology has established a general permit for boatyards, which allows facilities to obtain a permit with certain set requirements rather than having Ecology issue an individual permit tailored to each individual facility. Individual facilities which receive coverage under the general permit are required to comply with all terms and conditions included in the permit.
Who Must Comply?
The general permit would apply to all service businesses primarily engaged in the construction, repair, and maintenance of small vessels, if 85 percent of which are 65 feet or less in length. The boatyard activities covered by the general permit include, but are not limited to: pressure washing, bottom and top side painting; engine, prop, shaft and rudder repair and replacement; hull repair, joinery, bilge cleaning; fuel and lubrication system repair or replacement; welding and grinding on the hull; buffing and waxing; top-side cleaning; marine sanitation device repair or replacement; and other activities necessary to maintain a vessel. Marinas that conduct boatyard activities also are required to obtain the general permit. It is important to note that the general permit does not cover ancillary or related industrial or commercial facilities, such as a repair shop for marine engines. Those facilities may require coverage under the Industrial Stormwater General Permit.
Any facility may request to be excluded from coverage by the general permit by applying to Ecology for an individual permit. The applicability of the general permit requirements to a facility will be terminated on the effective date of the individual permit.
What Would the Proposed General Permit Require?
For the revised general permit, Ecology has included “benchmarks” which are indicator values — not water quality standards or permit limits. When a sample result exceeds the benchmark value, then the general permit requires certain responses based on the number of samples which exceed the benchmark value (i.e., inspection of the facility and use of additional best management practices if appropriate).
Annual monitoring of stormwater has been a requirement of the previous boatyard general permits, however Ecology has determined that compliance with the monitoring requirement was poor. Therefore, Ecology has increased the monitoring requirement to five samples per year in the revised general permit (four samples in the spring and fall and one sample in January).
The revised permit also will require facilities to develop and maintain a Stormwater Pollution Prevention Plan (SWPPP), specifically developed for the facility. The SWPPP will include the required BMPs and document the technical basis for selection of all stormwater BMPs. In addition, the SWPPP will include a monitoring plan for the facility, identifying all points of discharge to the sanitary sewer, surface water, and storm drain system. The general permit requires use of BMPs to prevent pollutants from getting into the wastewater/stormwater. BMPs are required to be adopted by a facility if they are appropriate. The revised general permit has included the use of vacuum sanders for removing paint to the list of required BMPs. Other facility specific BMPs are expected to be developed by each facility in order to meet the permit benchmarks. The BMPs will be listed in the facility’s SWPPP.
Reporting and treatment requirements for zebra mussels, an exotic species, also are required by the general permit. This includes inspection, reporting and quarantine requirements.
As previously noted, Ecology will consider comments regarding potential changes in the general permit requirements if such comments are filed with Ecology by June 27, 2005. Boatyard owners or operators with an interest in the revisions to the general permit requirements are encouraged to file comments with Ecology within the deadline. Public hearings will be held at the Ecology Headquarters in Lacey, Washington on June 21, 2005 and at the Snohomish PUD Headquarters in Everett, Washington on June 22, 2005. Oral comments may be delivered to Ecology at the public hearings.