12 NATCHEZ ON THE WATERFRONT
The ins and outs of power washing By Dan Natchez*
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or most full and partial service facilities, and increasingly at many boat ramps, cleaning the hulls of boats is a normal and necessary activity to remove dirt and marine/aquatic growth, whether that growth is simply unwanted or potentially harbouring an invasive species like zebra or quagga mussels. These days, the cleaning often involves some form of power/ pressure washing (we’ll stick with ‘power’ here), with or without some form of detergent or biocide mixed in. During the washing, we often also end up removing some oil and grease or other chemicals as part of the dirt and loose paint. We also use power washing to intentionally remove bottom paints. We have all seen a boat that is being power-washed after being
A hard surface pad has to be reinforced. MARINA INDUSTRY • JUNE 2022
hauled at the end of the season and the power wash water turns the colour of the hull’s bottom paint. I recall years ago a marina manager jokingly telling me that he only allowed boats with blue and green hulls to be hauled at his facility, so he could help turn the harbour waters back to a nice blue-green colour! In fact, in the not-too-distant past, and to various extents still today (particularly depending on what part of the country/world you live in), most of us didn’t give too much thought as to where the water from this kind of boat washing was going. That began to change as the attention of the regulatory world started heading from the big smoking gun types of water pollution to ‘non-point source’ and ‘storm water associated with industrial activities’.
Suddenly, marina operations were industrial activities, even if most of us had a hard time thinking of this often-romanticised pursuit in this way. I also recall an off-the-record conversation with the head of an unnamed North-Eastern state’s environmental protection agency, where, as we were discussing storm water runoff, I asked: “Well, what about the power washing water?” He replied, “Don’t ask that question. We don’t really have a good way to permit it and you won’t like the answer I’ll have to give you”. All these years later, most places, at least in the US, still don’t have a good way to permit it, but it is officially recognised as ‘process water’ (ie, industrial process wastewater) and something that cannot be discharged either to surface or ground waters
without a permit. Keep in mind that any water associated with wet sanding is also considered process water and similarly regulated. Like many regulations, those covering process water are subject to various degrees of enforcement, which seems to go in cycles, and interpretation as to what is in compliance (with either or both the letter of the laws or the interpretation of the laws). What was considered compliant years ago might not be considered compliant any longer! In most cases in the US, the ‘bad’ (or at least not preferred) way to permit these types of discharges would be to get a facility specific individual industrial discharge permit, which most facilities consider far too burdensome an approach (and regulators most often agree). So,
