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Environmental Roadmapping Initiative -- Shipbuilding and Ship Repair

Baseline Environmental Performance Measures for the Shipbuilding and Ship Repair Industry

Prepared August 2001 by John Sheridan, NCMS, (734) 995-4963, johns@ncms.org 

Introduction and Executive Summary

• Introduction

• Executive Summary

Introduction

This report provides information that will assist in determining baseline performance measures for the industry, with the ultimate goal of creating a framework within which environmental progress in this sector can be measured. Shipyards are already reporting relevant environmental data to federal and state environmental agencies. Such data would constitute a valuable starting point for establishing a baseline. Specifically, the report seeks to identify already-reported data on performance, and best practice, in the following areas. Each is addressed in the named parts of this report:

• Part One: VOC emissions
• Part Two: Storm water metals loadings
• Part Three: Generation an off-site transportation of hazardous waste

Summary of State Data Available[1]

See Appendix 2:  Where the Shipyards Are for rationale on selection of states

The “yes” and “no” notations below respond to the question: “Are there state databases with environmental performance measures for {the column headings}?”

  * Features of this state program are noteworthy.

Executive Summary

For the purpose of determining baseline performances measures for the industry in all three areas, the clearly consistent source of data is federal EPA reports. All the states follow the EPA reporting requirements.

In contrast, for the purpose of encouraging best practices, it is instructive to examine the outliers. Here, a number of innovative state programs deserve mention. They are summarized below.

Assessment of State VOC data

Basis for performance measures

All states follow the EPA Clean Air Act reporting, which has been available since 1991. The Clean Air Act addresses only major sources.

Outliers

The Connecticut Air Toxics Control Regulation deserves special mention. In 1986, Connecticut adopted the most comprehensive regulation, at the time, in the United States to control toxic air pollutants. This regulation established emission limits for 850 chemicals based on national occupational health standards. Compliance with these limitations is verified through engineering calculations, periodic testing and inspections conducted by the Department's enforcement staff. Following the passage of the 1990 Clean Air Act Amendments, with its MACT requirements, the Department decided to retain the existing state regulation for control of air toxics as well as to implement the required federal MACT program.

Assessment of State Storm Water data

Basis for performance measures

All states follow the EPA NPDES program. Data for this program starts after NPDES Phase One in 1990.

Outliers

It is useful to review

• Oregon’s Best Management Practices for Oregon Shipyards
• Oregon’s Recommended Best Management Practices for Storm Water Discharges
• Connecticut's “Clean Marina” Programs described in more detail below

Washington State is also particularly advanced in their storm water program. State Ecology experts assert that Washington State’s program to protect the environment is especially effective. Washington State has published valuable research on water quality criteria for wastewaters, particularly screw lift dry dock floodwater discharges, and storm water discharges. Three documents are attached to this report as Appendices.

1. National Pollutant Discharge Elimination System Waste Discharge Permit No. WA-003104-6, for Pacific Fishermen, Inc., May 1997, pages 6-10, (Washington 031046F2.DOC), provides an excellent, detailed review of discharges from shipyard drydocks, including EPA efforts, waste water monitoring efforts in specific shipyards, Washington State requirements, and Maritime Industrial Waste Project results. It concludes that best management practices, rather than monitoring, will provide a real incentive to dry dock cleanup.
2. Fact Sheet for NPDES General Permits for Boatyards, July 97 (Washington BOATFACT.DOC) explains the nature of the proposed discharge, Ecology’s decisions on limiting the pollutants in the wastewater, and the regulatory and technical basis for those decisions.
3. Boatyard National Pollutant Discharge Elimination System Waste Discharge Permit, December 1997, (Washington BYPER4A.DOC) documents storm water monitoring criteria for the State of Washington.

Assessment of State Hazardous Waste data

Basis for performance measures

All states follow the federal EPA RCRA rules, which are mature.

Outliers

It was noted that Maine, Louisiana, Oregon, and Texas (and perhaps others) require annual reporting of hazardous waste generation (Federal RCRA requirements are biennial).

In addition to hazardous waste reporting, Oregon was one of the early states (since 1989) to become involved in pollution prevention programs through facility planning. Their Toxics Use and Hazardous Waste Reduction Plan requires an Annual Progress Report by large quantity generators of hazardous waste or large toxics users. This plan has since been emulated by many other states.

Clean Marinas Programs[2]: a Multimedia, Multi-state Approach

Inquiries in Connecticut brought to light the fact that many states have been developing innovative “Clean Marina” programs. These programs are apparently modeled after initiatives that first started in Maryland and Florida. Similar initiatives now also exist in Tennessee, Texas, and Virginia. Related efforts exist in California and Maine.

“Clean Marinas” programs are voluntary, incentive-based, education and outreach campaign to encourage environmental compliance and the use of best management practices. These efforts are led by State Environmental Agencies and Trade Associations to provide incentives to marinas to meet and exceed compliance requirements in exchange for positive recognition and marketing support. These multi-media efforts address air, water, and solid waste concerns. In Connecticut, this cooperation extends across all marinas, inland and coastal, and is supported by the Connecticut Marine Trade Association.

More detail about Clean Marina programs and contact information for other states is provided in Appendix 7.