NATCHEZ ON THE WATERFRONT

The ins and outs of power washing

By Dan Natchez*

For 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 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,

It also needs to incorporate a slope.

what does a marina operator or boatyard owner do?

There are many options a facility can take, ranging from relatively inexpensive to very expensive. What makes the most sense for your facility will depend greatly on your specific operations, as well as the associated regulatory and physical environments. ● Do nothing. There are definitely facilities that have yet to really tackle the problem and in many places enforcement has been somewhat lacking. However, when an agency decides to conduct on-site inspections, the opening notice of fines can be equal to or higher than the cost of compliance. In most cases, it is also in the facility’s best interest to minimise its potential negative impact on water quality and the environment. ● Only conducting power washing in an area where one has covered the ground with filter fabric and/or surrounded the area with hay bales, thereby allowing the collection of the biggest debris and allowing the water to flow directly into the ground or over the surface to the water. Years ago, this was sometimes considered enough and while better than nothing, in most cases would be hard to justify as compliant – not that the use of filter fabrics can’t be part of a system or overall approach. Such largely untreated discharges can also lead to potential ground contamination issues. ● Most of the other options will all entail having a wash pad of one form or another and involve preventing any discharge of process water, thereby eliminating the need for a discharge permit.

Different approaches

These include collecting the wash water from your pad, with or without some basic filtering, and directing it to a holding tank that will be pumped out by a certified haulier and properly disposed of. For facilities that do not do much power washing, this can be a solution, but for facilities with any kind of volume it may prove impractical, not cost-effective and too expensive.

Another approach is pre-treating wash water and directing it into a sanitary sewer system – sometimes referred to as an ‘open loop’ system. This can be an attractive set-up, particularly where a municipal or similar sewage treatment plant is at the end of that sanitary

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sewer line. There is normally a requirement to obtain permission for the discharge and the pretreatment requirements of the sewage treatment plant owner can vary tremendously. These can range from simply having some basic filters (down to a reasonable micron level) and a settling tank of some sort to the more advanced treatment methods that would be used in almost any closed loop/ recycling system, although even in the latter case the overall level of treatment required is typically less than for a recycling system since the treatment is finished at the sewage treatment plant. Some plant-owners require some level of periodic testing of the water you are sending their way, some do not. There is also the risk that the plant-owner will change his mind at some point and either disallow the connection or increase the pretreatment requirements.

A third option is a closed loop/ recycling system. While this approach can be similar to the ‘open loop’ system, it most usually requires a higher level of treatment, so as to sufficiently finish the water for further pressure washing use. Similar to the ‘open loop’ system there will be filtration down to specified micron levels. Depending on the intensity of use and the particular climate, these systems will often include continuous movement of the water within the loop to prevent stagnation and/ or the addition of an ultra-violet or bromide system to prevent bacterial growth in the water and foul odours. Some systems use flocculation additives (to encapsulate foreign materials). In most cases, and where they can be afforded, recycling systems are considered the preferred and ‘greenest’ means for dealing with power washing process water, particularly in places where fresh water is in scant supply or expensive to obtain.

There are many variations on a theme for the above-described approaches and the cost can range from relatively little to hundreds of thousands of dollars. The latter is usually for very intense activities and a highly customised system. The actual treatment processes vary considerably, ranging from electro-coagulation to ceramic media, carbon filters, cyclonic separators, etc, and a host of mechanical filters. Each system can have its strengths and weaknesses. When talking with vendors make sure they understand your needs and whether you are in a salt or fresh water environment. Ain addition, obtain clear answers as to how you will be able to dispose of collected solid wastes, used filters, etc. There are quite a few suppliers out there these days, though most are geared towards the carwash, trucking, heavy industry and/or military markets, which tend to be on the pricier end, and relatively few that are focused on marinas (not that this means they can’t supply a marina). Each company has its particular focus with pluses and minuses. Two US suppliers that are particularly marina-focused are EMP Industries (makers of the AquaClean system) and The Next Generation in Waste Water

These washdown racks with washer recycler unit from Hydro Engineering Inc (HE Inc) create a contained system that is on/above ground.

There are many options a facility can take, ranging from relatively inexpensive to very expensive. What makes the most sense for your facility will depend greatly on your specific operations, as well as the associated regulatory and physical environments.

Treatment Technology. There are several companies overseas that also cater to the marina industry.

Hard surface

Fundamental to any treatment system is having the means to collect the water. In most cases, it is strongly recommended that the power washing be undertaken on a hard surface that is sloped to a catch basin where a sump pump can be placed to transfer the water to a tank or whatever treatment system is employed. For a new facility or one that is already renovating their mobile boat hoist operation or launching ramp, that is a relatively simple approach to undertake. However, it can be very expensive to redo or retrofit an existing hard surface pad. Not only does it have to be reinforced to withstand the weight of the mobile hoist and boats that are being hauled or launched, but it also needs to incorporate a slope, so that water is directed towards the catch basin. In all cases, there should also be an approach to separate the process water from storm water when the process water is not being created and, in an ideal world, minimising the amount of storm water that runs on to or across the pad from other areas.

For facilities where creating these types of fixed pads is not possible, whether financially or practically, there are now special washdown racks and tarp-like pads available to create a contained system that is on/above ground. One supplier of such systems is Hydro Engineering Inc in Utah. While its focus for recreational boating has been on boat decontamination to prevent the spread of invasive species, it also provides washdown and treatment systems for an extensive range of applications.

Grant assistance

For decades we have been advocating that grant money be made available to facilities to help provide a greater incentive to undertake such upgrades. We all need and want clean water or there will be no recreational boating industry and some states have provided limited, small grants to help provide incentives. In the US, the Clean Vessel Act, administered through the US Fish and Wildlife Service, provides incentive grant monies for pump-outs. This program has been in effect for many years and has been extremely effective in not only creating a network of pump-outs throughout the country, but also stimulating upgrades and improved operations. It has been so successful that many states are unable to spend all of their allocations.

Many, including my own consultancy, have been advocating for the broadening of the program to cover process water initiatives. The cost of constructing a suitable washdown pad and meaningful system to handle the process water can typically range from approximately $50,000 to $100,000 depending upon the location and various regulations. If one moves into customised systems or needing to meet extremely minute standards – the costs can skyrocket. Regardless, compliance is not an insignificant cost to marinas, particularly when one considers that it is estimated that over 70% of the 10,000 to 12,000 marinas in the US have less than 100 boats, with most being less than 50 boats.

We again urge the various marine associations (local, state and national), to renew their efforts to make this a major priority and we are willing to help. We recognise that there are always numerous demands for how monies, and particularly incentive grant monies, are to be spent and what programs end up being funded, but if one really wants to make major inroads in helping marinas improve water quality, one of the most significant cost/benefit results would be to fund incentives for the treatment of process water.

*Dan Natchez is President of Daniel S. Natchez and Associates Inc, a leading international environmental waterfront design consulting company specialising in the design of marinas and marina resorts throughout the world. Your comments and enquiries are invited on Tel: +1 914 698 5678, by Fax: +1 914 698 7321, by E-mail: dan.n@ dsnainc.com or on his Website: www.dsnainc.com

DANIEL S. NATCHEZ and ASSOCIATES, Inc.

An International Environmental Waterfront Design and Consulting Company

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