Baseline Environmental Performance Measures for the Shipbuilding and Ship Repair Industry

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

Data, Part Two: Storm Water Metals Loadings

Federal Storm Water Programs

The National Pollutant Discharge Elimination System (NPDES) Permit Program, Phase One, addresses storm water[9] discharges for municipalities, construction, and industrial sites. In most cases, the NPDES permit program is administered by authorized states. Different monitoring and control processes are used for different industrial situations within the NPDES program. The primary method to control storm water discharges is through the use of best management practices[10]. Facilities that meet the definition of storm water discharges associated with industrial activity found in the Code of Federal Regulations (CFR), Part 40, Section 122.26(b)(14)(i)-(xi) must be covered under a NPDES industrial storm water discharge permit. Covered industrial facilities report storm water discharge contents in accordance with EPA Form 2-F[11]. This form lists the metals and other contaminants that must be reported. Of note is the fact that copper is not included.

Summary and 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[12] 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.

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.
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.
Boatyard National Pollutant Discharge Elimination System Waste Discharge Permit, December 1997, (Washington BYPER4A.DOC) documents storm water monitoring criteria for the State of Washington.

Connecticut also has a very new Clean Marinas program. However, no information is available about this program on the web. It appears that the publication Boating in Connecticut - Action Guide for Boaters can be ordered from Connecticut DEP.

State Data Available on Storm Water Metals Loadings

The following paragraphs provide information on the status of the selected state storm water programs. States are presented in alphabetical order. Information about significant state databases is presented in a table. Other states are covered in narrative format.

Alabama	Florida	Mississippi	Virginia
California	Louisiana	Oregon	Washington
Connecticut	Maine	Texas

Alabama[13]
Are there state data?	Yes. The Alabama Department of Environmental Management, Industrial Program develops and regulates the NPDES program for industrial sources in Alabama. General permits are issued for most facilities. There are certain circumstances where a general permit is either not available or not applicable to a specific facility. In this type of situation, a facility operator must obtain coverage under an individual permit that the NPDES permitting authority will develop with requirements specific to the facility. Alabama NPDES permit number ALG030000 is a general permit authorizing discharges associated with boat and shipbuilding and repair industries.
For what years is data available?	Since 1993.
Data for both small and large facilities?	Yes. Alabama maintains data for both large and smaller facilities, and both general and individual permits.
Data easily aggregated to SIC?	Yes. The data is self-reported by the shipyard.
Are data in similar units?	Yes. Data are consistent with other NPDES reporting. Effluents, units, discharge limits, and monitoring frequency (generally every 6 months) are contained in the above cited permit, in section DSN001.

California

The California State Water Control Board administers the state’s industrial storm water program. The program is described at http://www.swrcb.ca.gov/stormwtr/industrial.html. Shipbuilders are among the regulated SIC codes. Shipbuilders are permitted and file annual reports with CA SWRCB, but the state does not compile these data in any database, nor do they impose numerical limits on the shipyards. It was suggested that the individual yards might have good records in this area.

Connecticut [14]
Are there state data?	Yes. Connecticut has few shipbuilders, but one is very large. They require each permitted facility to take annual samples and self-report data. They maintain a database of such data.
For what years is data available?	Since 1992.
Data for both small and large facilities?	Yes. There are also data for marinas (SIC 4493), in addition to ship and boat building and repair.
Data easily aggregated to SIC?	Yes. The data is self-reported by the shipyard.
Are data in similar units?	Data include concentrations of lead, zinc, and copper, nitrates, phosphorous, oil & grease, coloform bacteria, aquatic toxicity, and more.

Florida

No storm water data is collected for industries.

Louisiana

No storm water data is currently collected for industries, nor has it been collected in the past. Louisiana is planning[15] on a new permitting system that would cause data to be collected. This system is some years away from implementation.

Maine

Maine has recently become an EPA permit authority under the NPDES system. They are just now implementing that program throughout the state. No state data exist beyond EPA NPDES Permit Compliance System data.

Mississippi

Mississippi complies with the NPDES program. The Baseline Industrial Storm Water Permit is available here. Parameters to be measured are on page 9 of the document. The Guidance Manual for Industrial Facilities is also found under “Industrial Guidance Manual” on this same page. The state has an EPA grant for a One Stop Data Integration Plan, described here.

Oregon
Are there state data?	Yes. Oregon maintains NPDES data. The Wastewater Permits Database has been put online to allow the public to search DEQ's Source Information System (SIS) database for information on NPDES and WPCF[16] permits. It contains records from DEQ's Source Information System current through 8/10/01.
For what years is data available?	Data are likely available for at least five years back.
Data for both small and large facilities?	Yes. There are 830 industrial storm water permits currently issued in Oregon.
Data easily aggregated to SIC?	Yes. The data is self-reported by the shipyard.
Are data in similar units?	Data are consistent with NPDES requirements

See Best Management Practices for Oregon Shipyards

See Oregon’s Recommended Best Management Practices for Storm Water Discharges

Texas[17]

The Texas permitting system is in transition. In 2001, TNRCC proposes to issue the Texas Pollutant Discharge Elimination System (TPDES) general permit for water discharges. The TNRCC is proposing a general permit that is reasonably consistent with the EPA's MSGP. No state data are planned beyond EPA NPDES Permit Compliance System data.

Virginia[18]
Are there state data?	Yes. EPA has authorized Virginia to issue NPDES permits. These permits, when issued by Virginia, are called Virginia Pollutant Discharge Elimination System (VPDES) permits. Virginia’s major shipbuilders are concentrated in the Tidewater area, where shipbuilders respond to a permitting authority, compliance and inspection activities. Extensive data are available in this region..
For what years is data available?	Data from the past five years are available electronically, and include dissolved metals. Even more detail, and older data are available on paper.
Data for both small and large facilities?	A qualified yes would be appropriate here. Virginia is home to some of the nation’s largest shipyards. Data are collected for these facilities and commercial yards, including smaller commercial facilities. DEQ does not maintain data for marinas and small boat facilities. However, the Virginia DCNR does have a “Clean Marinas” program with data for these smaller facilities.
Data easily aggregated to SIC?	Yes. The data is self-reported by the shipyard.
Are data in similar units?	Data reporting is addressed in 9 VAC 25-31-120. Storm water discharges include concentrations of zinc, copper, nitrates, nitrites, phosphorous, oil & grease, and other pollutants that must be reported under the EPA form 2F.

Washington[19]
Are there state data?	Yes. Washington State is particularly advanced in this area. State reps assert that they have been criticized for holding Washington shipbuilders to higher standards than others. The counter point is that other states should not be so lax. Washington conducted a survey in 1997 of all shipyards in the US, preparatory to establishing Washington State law on this area.
For what years is data available?	Data are available electronically since about 1992.
Data for both small and large facilities?	For ships (>65’ length) Washington does collect numerical data on storm water. This data includes metals loadings, and is available in a database. Boats (<65’) are under a different permit system, but also report data.
Data easily aggregated to SIC?	Yes. The data is self-reported by the shipyard four times per year.
Are data in similar units?	Data formats are not available online. Formats are being sent by mail.

Environmental Roadmapping Initiative -- Shipbuilding and Ship Repair