2009 ENVIRONMENTAL SEMINAR Boat Bottom Pressure Washing Requirements & General Permit for the Discharge of Stormwater Associated with Industrial Activity Tuesday, August 18, 2009

Management of Vessel Pressure Washing Wastewater

Spring 2006: Discharge of pressure wash water to surface or ground water no longer allowed December 31, 2008: Original deadline to cease discharge May 2008: DEP publishes guidance for pressure wash water management September 30, 2009: Deadline extension March 2009: After much negotiation with DEP to extend Sept. deadline, CMTA sends letter to legislature and Consent Order is negotiated Quick History of the Issue

DEP Guidance on Boat Bottom Pressure Washing (as of May 2008) Contain & collect wastewater deflected from any boat surface during boat bottom pressure washing. Wastewater cannot be discharged to ground or surface waters Handle wastewater as “process wastewater.” Process wastewater is not covered by the Stormwater General Permit and cannot be discharged to ground or surface waters

PW WASTEWATER MANAGEMENT OPTIONS COLLECT, TREAT & PIPE TO SANITARY SEWER Treat water in compliance with General Permit for Miscellaneous Discharges of Sewer Compatible Wastewater (“MISC General Permit”) and regulations of municipal water pollution control authority COLLECT, TREAT & HAUL TO SANITARY SEWER Transport water by the marina operator, or by a contract hauler licensed under CGS Section 22a-454 for discharge to a municipal sewage treatment plant in compliance MISC GP & local regulations COLLECT & HAUL TO INDUSTRIAL WASTEWATER TREATMENT FACILITY Collect wastewater in a tank and transport by licensed waste hauler to licensed industrial wastewater treatment facility

* Facilities must either cease discharge of pressure wash waste water by September 30, 2009 or enter into Consent Order Agreement with CT DEP to extend deadline to December 31, 2010

YOU DON’T HAVE TO SIGN THE CONSENT ORDER If you don’t sign the consent order, you must: 1. stop discharging pressure wash wastewater to ground or surface water; or 2. stop pressure washing boats… BY SEPTEMBER 30, 2009

IF YOU DO SIGN THE CONSENT ORDER If you do sign the Consent Order, you must: 1. Officially sign onto Consent Order by September 15, 2009; and 2. abide by the Terms and Conditions of the agreement and complete all enforceable milestones BY DECEMBER 31, 2010

Implement 2002 Clean Marina BMPs for pressure washing Submit copy of Exhibit A to Ed CT DEP’s Water Permitting & Enforcement Division, to officially enter into Consent Order Prepare & complete all plans and specifications for project File all state and local permit applications (including COP) Obtain all state and local permits, licenses & approvals File Miscellaneous General Permit registration, if required Submit Reporting & Certification Form to CT DEP describing timeline, certifying interim BMPs implemented & actions complete Cease all unpermitted discharges of pressure wash wastewater Submit Reporting & Certification Form to CT DEP certifying that all actions have been complete or certifying that PW discharges have ceased TIMELINE FOR CONSENT ORDER

Pad constructed of impervious material coated with a sealant DEP GUIDANCE ON PAD DESIGN Designed to minimize stormwater running on to the pad NOTE: 1) Pads constructed to allow stormwater to overflow when not pressure washing are considered a point source and subject to the conditions of the Industrial Stormwater General Permit. Process wastewater should not overflow or run off the pad at any time, nor should it accumulate and discharge to ground or surface water Lockable valve, watertight cover or plug, or dedicated power source that can be secured is required for pumps used to divert stormwater sump Stormwater discharge Discharge to tank or sanitary sewer EXAMPLE ONLY-NOT FOR CONSTRUCTION

Post signs outlining proper operation DEP GUIDANCE ON OPERATION & MAINTENANCE Sweep and rinse pad prior to activating stormwater diversion NOTE: 1)O&M for pad must be identified in SWPPP, included in weekly inspections, staff training, stormwater monitoring including sample location and procedures 2)Inspection of pad must be included in Comprehensive Site Compliance Evaluation as part of SWPPP Secure stormwater conveyance prior to pressure washing. sump EXAMPLE ONLY-NOT FOR CONSTRUCTION Maintain equipment, including hoses, to prevent discharges. Leaks from hoses and equipment are considered process wastewater discharges. Use a minimal amount of pressure & water Transport resulting solid waste to a permitted waste disposal facility Discharge to tank or sanitary sewer Stormwater discharge

DEP Guidance on Managing Overspray * No need to contain overspray as long as water source is a potable water supply and no additional chemicals or pollutants are added *If chemicals are added (eg., treated recycled water source), no collection necessary if the wastewater meets the target criteria for copper, lead and zinc as specified in the Stormwater GP. The discharge of recycled water from a pressure washing gun must not exceed the following concentrations : Copper1.3 mg/l Lead0.04 mg/l Zinc0.50 mg/l Photo credit: Thomas MaGuire, Massachusetts Department of Environmental Protection “process wastewater” “overspray”: the incidental spray discharged from a pressure washing gun during boat bottom pressure washing activities that does not come into contact with any boat surface, including any that may drift by air current away from its point of origin

Facilities that do not sign on to the Consent Order will be subject to the full enforcement authority of DEP as of September 30, 2009 *