Pressure washing regulations

[fordo]

I have been told, by the marina where I winter the boat that, because of new EPA regs, I cannot use a pressure washer on the hull where the bottom paint is. This I understand, the water must be captured to prevent the bottom paint toxins from flowing into the water. Can I pressure wash the deck, the bilge or the inside of the hull? They didn't know. One uses a pressure washer to clean with less detergent, fewer chemicals and less runoff than with a bucket, brush and hose.

Does anyone know what the new regs are?

[GaryHLucas]

I've been involved with this in NJ. The marina where I keep my boat asked for my help on this because I work in industrial waste water. I've read the regulations that went into effect in NJ this year. However they were supposed to take effect around October of this year, but because of the recession the rules ARE in place, but won't be enforced until next year. This lets marina clean boats this fall, but not next.

The reason I was asked to get involved is because the marina owner has been attending sessions about this issue at the NJ marina owners association. He told me that so far, no one has demonstrated a workable system for dealing with the runoff water from boat cleaning.

I have reviewed, and passed along to others for review, all the systems presented to the NJ marina owners. We've concluded that none of these plans are workable, and the marina's have good reason to be really worried.

The company I work for could in fact build a workable system, we do it all the time in our industrial waste treatment business. Doing it on a small scale for individual marinas, to be operated by the typical marina personnel, well that is a whole different story.

The bottom line here is that the new regulations forbid ALL discharge of boat cleaning water into any waterway. It also sets BOD (Biological Oxygen Demand, or Organics) and strict chemical, primarily metals, discharge into sanitary sewers. BOD, the algae, barnacles, and slime, by themselves would be easy. However, because the whole goal of bottom paint is to kill that kind of stuff, biological treatment would be very difficult if not imposible. Metals are a different issue, and are very difficult to do.

I believe most marinas will be forced to truck the water to industrial waste handlers at a cost of about $1 per gallon. You will see that cost get added to the cost of washing your boat every time it comes out of the water.

Gary H. Lucas

[jjablonowski]

So I asked an environmental engineer who used to work with the NJDEP to comment about the policy, and he wrote back:

- the referenced rule change appears to be NJ only: NJDEP-New Jersey Clean Marina Program-Update for Marina Owners-Regulatory Changes Regarding Wash Water
- it includes a link to a list of 28 vendors selling treatment systems
- finding the actual requirements was quite hard; they're lost in a flood of guidance documents and voluntary programs
- not a new EPA reg, but part of the back-and-forth between federal EPA and the states in implementing the Coastal Zone Act Reauthorization Amendments of 1990.

His bottom-line comment: "NJDEP is broken, a shame because they used to be pro's."

[pschoonveld]

CT has passed a very specific law requiring that all run-off from boat bottom cleaning be treated and the first phase went into effect earlier this year. You can no longer scrub your bottom while in the water, either.

I understand and agree with limits on these things, but not cleaning hulls is just crazy.

[GaryHLucas]

I see the company I work for on the list. Somebody must have passed along my business card. I've looked at the NJ discharge limits, and I visited most of the 28 companies web sites to see what they are offering. Some of them can do the job, but I'd say that 75% of the companies listed are clueless as to how difficult this is going to be. If it was as easy as most of them purport WE wouldn't be in business, we'd be way to expensive.

Gary H. Lucas

[dvzee1]

Life long New Jersey Resident, this government is totally out of control with no prospects of getting well. I love where I live but am thinking about moving to a state where they may care about their constituents, if it exists. NJ has too many takers and not enough givers.

[hellosailor]

The technology is old and easy off the shelf, the only question is how the pols with screw it up.

You could put your boat in jackstands in a 40' above-ground vinyl swimming pool, blast away to your heart's content, and let the pool filter suction up all the residue then ship the filter tank out as toxic waste--once it filled up. The rest of the water could be treated or reused quite a while.

Or you can lay an impervious pit (concrete, clay, plastic linings) in the ground, same as used for any hazmat pondings, and then put some scavenging pipes in the bottom to allow the water to be sucked up and reused and filtered. Fill with gravel to support the weight of jackstands and boat.

Either way, any way, it will mean that either the marina installs "bottom washing stations" which could be a reasonable profit center, or they place an impervious lining under the entire storage area and deal with a bigger issue. Or, they ban bottom work. Which many yards have done for 20 years now, because they just don't want to bring in bulldozers and graders and strip off and replace their top two feet of soil and gravel--as some DID under EPA ORDER.

I've just been surprised to see how slow most marinas were in learning that the sky was gona come crashing down on them.

[catamount]

The places I've hauled out in Maine and Massachusetts essentially have "bottom washing stations" sort of like those described above. Basically a concrete or asphalt pad sloped so the water runs off to a drain where it is collected rather than allowing it to run off into the sea. There are small dams around the pad that prevent the water from running away from the pad area. These are located right where the travel-lift or crane would first land when hauling the boat out. What I'm not sure about is exactly what they do with the water that they collect from these drains, but I suspect that it is filtered and recycled back to the pressure washer for use again.

[Gene Smith]

Atlantic Highlands had a working system when I was there in July.
It was working well. Smelly though!

[GaryHLucas]

Originally Posted by hellosailor

The technology is old and easy off the shelf, the only question is how the pols with screw it up.

You could put your boat in jackstands in a 40' above-ground vinyl swimming pool, blast away to your heart's content, and let the pool filter suction up all the residue then ship the filter tank out as toxic waste--once it filled up. The rest of the water could be treated or reused quite a while.

Or you can lay an impervious pit (concrete, clay, plastic linings) in the ground, same as used for any hazmat pondings, and then put some scavenging pipes in the bottom to allow the water to be sucked up and reused and filtered. Fill with gravel to support the weight of jackstands and boat.

Either way, any way, it will mean that either the marina installs "bottom washing stations" which could be a reasonable profit center, or they place an impervious lining under the entire storage area and deal with a bigger issue. Or, they ban bottom work. Which many yards have done for 20 years now, because they just don't want to bring in bulldozers and graders and strip off and replace their top two feet of soil and gravel--as some DID under EPA ORDER.

I've just been surprised to see how slow most marinas were in learning that the sky was gona come crashing down on them.

Thank you, you've described the problem perfectly, because you clearly don't get it, and neither do the marina owners.

Conventional filters won't do the job, because they can only remove SUSPENDED particles down to about 1 micron. They can't remove any DISSOLVED particles. The crud that comes off the bottom of your boat contains both dissolved organics and dissolved metals. Generally if you have disolved organics you use a biological treatment system. However since you are also removing something DESIGNED (bottom paint)to make sure a biological process can't happen, that makes that kind of process very difficult. So then you need to remove the dissolved metals.

The dissolved metals removal requires physical chemistry, evaporation, RO or other similar solutions. All of those have a hell of time when there is lots of suspended solids to deal with. So this suggests you may need to use a two stage process.

My first job with this company involved metals removal at a steel tubing plant. We had to use RO to remove the hardness from the water at the front end of the plant combined with physical chemistry and ultrafiltration at the back end. Expensive process, $500K for the equipment. The previous physical chemistry process was failing to meet discharge requirements on a regular basis, and the water went to a local stream. They also produced 60 cubic yards of sludge hauled to a land fill every month. Our system always meets the discharge requirements, ussually by a very wide margin. They now send 2 cubic yards of sludge to the land fill each month!

And THIS is why in a tough economy I still have a good job!

Gary H. Lucas