Hull and deck cleaning, maintenance and repair are necessary activities that occur in most harbors and boat yards. However, even routine activities can generate significant amounts of hazardous wastes. Alaska Clean Harbors will provide boat owners and harbor staff with ideas and suggestions on how to perform these activities while minimizing the impacts on our marine environment.
Through the Alaska Clean Harbors program we focus on marina, or small boat harbor, operations. But if your harbor operates a boatyard as well, the BMPs in this and other sections will be applicable to you. We will provide some additional resources for you to use at your boatyard.
In this section we focus on vessel and hull maintenance, antifouling paints, engine maintenance and repair, winterization, boat hauling and storage, tidal grids, and boat washing. Even though your harbor might not have dedicated uplands for boatwork, many customers perform a variety of boat maintenance activities on the water, on the grid, and in the uplands - even in the absence of a dedicated boatyard. Always keep this in mind, and consider ways your facility can help customers perform their necessary work in a clean and safe manner.
Hull and vessel maintenance and repair are important services that may be done by contractors or by vessel owners and crew. Even routine services can generate hazardous and/or toxic wastes. For example, paint chips and dust generated during vessel sanding may contain heavy metals such as aluminum, iron, lead, nickel, zinc, cadmium, copper, tin and chromium. These and other heavy metals are known to accumulate in marine sediments. These pollutants tend to increase up the food chain, or bio-accumulate, which may lead to toxic food for humans.
Wastes generated through hull scraping, painting, hull washing, sanding or other vessel maintenance activities may be considered hazardous materials and if so must be disposed of in accordance with state and federal regulations for hazardous materials transportation and disposal [40 CFR 262.11, 18 AAC 62].
Your facility should be pro-active in communicating with customers and contractors the best practices required for boat work both on the water and in the uplands. Here are some examples of best practices and ‘yard rules’ from Alaskan harbors and boatyards to give you some ideas.
Sanding, blasting and scraping
In abrasive blasting, sand, glass or plastic bead, walnut sheets, metal shot or grid, sodium bicarbonate or dry ice pellets are used with air pressure or water pressure to remove paint. Traditional abrasive blasting of large boat hulls is a messy job resulting in many hundreds of pounds of spent abrasive mixed with bottom paint. While the abrasive can be relatively cheap, the labor is costly and the potential environmental impacts are huge.
Paint chips that can result from scraping or sanding often contain heavy metals that can be consumed by aquatic animals and moved up the food chain. All wastes generated from sanding, blasting and scraping may be considered hazardous and must be collected and disposed of properly.
We strongly encourage you to require tenting and tarping for debris-causing work at your facility. Debris from boat work can not only pollute the water and air, but it also can blow onto neighboring boats. Make sure your harbor staff are pro-active and helpful in working with customers to contain all boatwork debris. Take a look at the Tenting & Tarping binder that the Seward Harbor has in their Harbor Office to help demonstrate proper techniques for customers.
QUESTION: Does your facility require fabric underneath all vessels in the uplands? Do you prohibit abrasive blasting? If you allow it, do you require containment for any abrasive blasting or other debris-casuing boatwork?
Paint chips and dust generated during vessel maintenance activities often contains heavy metals like aluminum, iron, lead, nickle, zinc, cadmium, copper, tin and chromium. We know that heavy metals bio-accumulate in the food chain and they can be toxic to aquatic life, including fish and shellfish. Most paints contain volatile organic compounds (VOCs) that evaporate quickly and are ignitable.When released to the atmosphere, VOCs combine with combustion emissions of nitrogen oxides (NOx) to form ground level ozone, which damages lungs and degrades many materials. Marine paints may be toxic to aquatic and marine life.
Check the SDS sheets of paints and associated products to find out if they are considered hazardous waste.
QUESTION: Does your facility prohibit in-water paint scraping or any process that occurs underwater which removes paint from the hull?
Both big and small paint jobs are often going on in the harbor, both on the water and in the uplands. This extremely common activity is also one that can result in significant spills and lots of small drips if not done with care. Thankfully, some very easy and free good housekeeping measures can reduce, if not eliminate, painting spills and drips.
best practices for painting
- Use brushes and rollers instead of sprayers whenever possible. Paint spraying can be wasteful and can send more paint into the environment than applying by hand.
- If spraying, use paint guns that are high volume low pressure (HVLP) or high efficiency low pressure (HELP). HVLP paint guns can reduce overspray by 25% – 50%, reducing both your costs and the amount of paint introduced into the environment.
- Don’t paint on windy days, and make sure to use tarps and tents to provide protection when painting.
- Mix paints away from the water and avoid dripping into the water. Remember that paints are toxic to marine life and always practice good housekeeping when painting. Only mix as much paint as you need for the job at hand.
- When painting on the water, keep mixed open paint in small containers (less than one gallon) that can be tightly covered. Small containers mean small spills. Keeping containers tightly covered will prevent evaporation, which can reduce air pollution and saves product and money.
- Do not intentionally air-dry leftover oil-based paints. Evaporation of waste solvent or waste oil-based paint constitutes illegal disposal of hazardous waste and reduces air quality at your harbor.
- Collect all paint chips and dispose of properly. If you aren’t sure if the paint chips are considered hazardous or not, check the SDS sheets for the products you’re working with. Oil-based paint and paints containing heavy metals are considered hazardous materials and should be disposed of as such.
- If you don’t know where to take your waste products – ask your harbormaster! Especially at an Alaska Clean Harbors certified facility, your harbormaster and harbor staff should be a resource for you, the customer. If you don’t know where to take something (such as oil-based paint chips or spent solvents), ask at the harbor office.
Most paint strippers, cleaner and solvents associated with painting are identified as hazardous waste by characteristic (primarily ignitability) or because they are an “F” listed hazardous waste with components that include acetone, toluene, zylene, Methyl Ethyl Ketone (MEK) and ethylbenzene.
Educate all workers on the hazardous nature of solvents. Solvents can be costly for purchasing and disposal. Make sure any workers using solvents are aware of their hazardous nature. Most paint strippers, cleaner and solvents associated with painting are identified as hazardous waste by characteristic (primarily ignitability) or because they are an “F” listed hazardous waste with components that include acetone, toluene, zylene, Methyl Ethyl Ketone (MEK) and ethylbenzene.
best practices for solvents
- Use a two-stage cleaning process. When the first bath doesn’t clean, replace it with the second bath and refill the second bath with clean solvent. Properly dispose of spent solvent.
- Reuse solvents. Allow the solids to settle, then pour off and reuse the clean solvent. Use this reused solvent to do initial cleaning and save your new solvent for a final cleaning.
- Consider alternatives to chemical paint stripping. Based on the surface you are stripping, the type of paint being removed and the volume and type of waste produced, consider alternatives such as sandblasting, scraping and/or abrasive blasting. Use a heat gun to remove paint and varnish where appropriate.
- Print and post this list of alternative cleaners that your employees and customers might try.
- When using chemical paint strippers, consider using water- or soy-based products which are less hazardous.
- Clean paint guns in an enclosed gun cleaner and capture all solvents. Spent paint gun solvent must be treated as hazardous waste and should never be discharged into drains or onto the ground.
QUESTIONS: Do you limit on-water painting activities? Do you prohibit paint spraying on the water without protective sheeting? Do you actively promote painting best practices with your customers and contractors? Do you promote responsible use and disposal of solvents and other hazardous materials used in boatwork? Do you prohihbit in-water hull scraping or any underwater hull work that removes paint?
There are two basic types of antifouling paints: Ablative and Hard. Both types of paints have about the same impact on the environment over time.
Ablative bottom paints slough away with use. They contain a biocide, are partially soluble and wear away at a controlled rate.
Hard paints are also called “contact leaching” paints. As they dry, they create a porous film that contains biocides. The biocides dissolve in water when they are exposed.
All bottom paints that contain copper are legally registered pesticides.Tributyltin (TBT) is a regulated pesticide sometimes found in antifouling paints. Under the Organotin Antifouling Paint Control Act [33 U.S.C. 2401], the use of antifouling paints containing TBT is prohibited on vessels under 25 meters (82 feet) in length. Aluminum hulled vessels, which quickly corrode from cuprous oxide antifoulant coatings, are also allowed to use TBT. The state of Alaska bans the sale or use of TBT-based antifouling paints and “…nor may a person sell, rent, or lease in the state, or import into the state, or use in state water, a vessel, fishing gear, or other item intended to be partially or completely submerged in water, if the vessel, gear, or item has been painted or treated with TBT-based marine antifouling paint or coating.” [AS 46.03.715 (a)].
Understanding the different options available to customers can help harbor staff be more helpful when it comes to choosing less toxic bottom paints. It will also help you to understand the potential toxicity of paint chips and sandblasting waste from hull maintenance activities at your facility.
Non-toxic bottom paints contain Teflon or silicone to create a smooth and hard surface that reduces attachment of fouling organisms.
Insert a few links here for antifouling paint alternatives. Which links do you want? I’ve inserted a youtube video https://www.youtube.com/watch?v=29y18G5bzgY&t=35
Also included 3 publications: Staying afloat with Nontoxic antifouling strategies for boats
Making dollars and sense of nontoxic antifouling strategies for boats
What you Need to Know About Nontoxic Antifouling Strategies for Boats
Alternative Fouling Control Systems (Environmental option for bottom painting) 2008
QUESTION: Does your facility communicate alternative antifouling options to your customers?
Many harbors around Alaska have tidal grids available for customers. Grids allow vessel operators to inspect and, in some cases, perform hull work without hauling their boats out of the water. Through Alaska Clean Harbors, we ask that the harbor have some ground rules for operating on the grid, and that the rules are posted, communicated and enforced.
best practices for the grid
- Prohibit debris causing activities
- Require users sign an agreement to use the grid
Here are some sign examples from harbors we have worked with. (Haines, Homer signs)
Here are some examples of tidal grid User Agreements. Your harbor can use these agreements as models for creating agreements with your own customers.
QUESTIONS: Approximately how many customers use your tidal grid(s) per year? Does your facility have rules or guidelines for grid users that outline policies to reduce wastewater and debris from grid activities? Do you have signs at the grid that clearly outline your policies? NOTE - each of these should have N/A as an option, as not all facilities have grids.
Engine Maintenance and Repair
Vessel operators must perform routine engine and mechanical system maintenance to ensure good long-term boat operation. We encourage boaters to stay on top of maintenance to prevent spills and leaks from old hoses and seals. Maintenance and repair activities, if not done with care, can themselves be sources of spills. Make sure that your harbor office has information available for boaters, and you’re ready to talk about good housekeeping practices on the docks to prevent spills during routine maintenance activities.
Two major sources of pollution are oil and fuel spills during repairs, and improper disposal of used solvents. Both can be prevented by following basic best management practices, including practices for clean oil changes.
Click here for some handouts that you can print out and provide for boaters performing engine maintenance at your facility.
QUESTION: Are your harbor staff pro-active in communicating engine repair best practices with customers?
Winterization includes a variety of activities that play an important role in boat preservation. Naturally, customers want to do what they can to protect their investment from harsh Alaska winters. If some of these practices are not performed properly, the effects on aquatic life can be catastrophic.
What are the major concerns with possible pollution from winterization?
- Spills or dumping of glycol (antifreeze)
- Spills or dumping of used oil
- Spills or dumping of cleaning products
Winterizing marine vessels generally includes flushing the engine with antifreeze, changing oil, and cleaning holds and other areas on the boat. All of these activities produce waste products, from used oil to used antifreeze. Use information from Alaska Clean Harbors to engage with your customers, reminding them of best management practices and services available to help reduce pollution in the fall and spring from winterizing activities.
Antifreeze is the primary product used in engine winterization. There are two main types of antifreeze used: the traditional ethylene glycol (green) and the less toxic propylene glycol (pink). Although propylene glycol is preferred for its lower toxicity, it still has an impact on water quality and cannot be discharged into surface water or to the ground.
Antifreeze - what’s the big deal?
Antifreeze is generally made of glycol (either ethylene or propylene) plus anti-foaming agents and materials that help prevent the corrosion of metal. After running through an engine, waste antifreeze can contain various metals including lead, cadmium and chromium. Antifreeze is considered a hazardous waste. See our page on Used Antifreeze for more information on used antifreeze collection and disposal.
Ethylene glycol is highly toxic to humans and animals. This is not stuff you want lying around the docks!
While propylene glycol is less toxic than ethylene glycol, it does have very high BOD – biological oxygen demand. This means that when propylene glycol is introduced into the marine environment, it uses up large amounts of oxygen to decompose and so makes that oxygen unavailable to aquatic life.
Disposing of used antifreeze can be extremely costly. Talk to your customers and remind them that they can help control costs (and thus their moorage rates!) if they only introduce straight used antifreeze into collection containers. This reminder, along with similar reminders for used oil disposal, should go out regularly.
Communicate with your customers and remind them to avoid spills when winterizing in the fall. Again in the spring (and possibly a more important time), get the word out to customers and remind them that avoiding spills and discharges is important.
Give out Clean Boating Tip Sheets on Winterization and Clean Oil Changes. Especially in the spring make sure to have tip sheets available in the harbormasters office detailing ways boaters can avoid spills during their annual maintenance routines.
Train staff to watch for discharges. Make sure all field staff are aware of the possibility of discharges in the fall and spring related to winterization activities. Have a plan in place for approaching customers regarding discharges.
Consider radio and TV ads, and posters or signs around the harbor. In the spring, remind boaters to avoid spills when preparing for the boating season through media ads in local papers, on the radio, and through posters or signs around the harbor.
best practices for winterization work
- Use propylene glycol to winterize all systems except “closed” or freshwater cooling systems. Propylene glycol is less toxic then the green ethylene glycol, however it still should never be discharged! All antifreeze should be collected and disposed of properly.
- Minimize use of antifreeze where possible. Rather than using antifreeze, drain as much water from the water system as is possible. It may be possible to use air pressure to blow the lines empty. If there are traps that cannot be drained completely, use a diluted solution of water system approved antifreeze, such as propylene glycol.
- Properly store and dispose of used antifreeze. Make sure to securely store all used antifreeze in containers clearly marked “Used Antifreeze Only”. Dispose of at the harbor, or at the local landfill. Check with your harbormaster if you don’t know where to dispose of your used antifreeze. Remember that contaminated wastes (i.e. used antifreeze mixed with large amounts of water or oil, etc.) can dramatically increase the cost of disposal. This cost is paid by the harbor, and is ultimately reflected in moorage rates and other fees. Help keep costs down by properly storing and disposing of your used antifreeze and other wastes!
- Don’t drain into the bilge! Cleaning your bilge is a pain, and a contaminated bilge can lead to discharges of hazardous waste into the marine environment when your bilge pump comes on. Avoid polluting the water and hefty fines by minimizing wastes going into your bilge in the first place! Always keep a bilge sock or pillow in your bilge to absorb small spills and leaks.
- Check fittings and hoses for leaks. Make sure to inspect your systems to avoid leaks during the winter.
- Fill gas tanks to no more than 90%. In the spring, warmer weather will cause your gas to expand. Prevent fuel overflow by only filling your tanks 90%.
QUESTION: Do you provide customers with information on how to prevent pollution while doing winterization work?
Boat Hauling & Storage
If your facility hauls vessels, make sure that the area around your haul-out is clean and well-maintained. Keep up with maintenance on your lift, railway, or tractor for hauling to prevent spills when hauling vessels.
Boat shrink wrap is a high-value plastic. If a lot of shrink wrap is generated in your community, contact Alaska Clean Harbors to discuss opportunities for recycling.
QUESTION: Does your facility haul vessels? Do you store vessels on-site? Do you have best practices in place for preventing pollution while hauling and launching vessels? Is there a large volume of boat shrink wrap plastic used in your community?
Boat washing is a common activity in harbors during the warmer months of the year. Ideally, the wastewater from boat cleaning activities should not enter the harbor, spreading suds everywhere. Detergents are probably the most common pollutant associated with vessel cleaning activities. The ingredients of many cleaners are extremely toxic and if allowed to enter surface or groundwater can rapidly dissolve into the water and/or sediments and create toxic environments for marine life.
Under the Clean Water Act, it is illegal to introduce these chemicals, detergents and other boat washing products into the water, whether in the harbor or otherwise. Work with customers to minimize these discharges, with a goal of eliminating visible suds in your harbor from boat washing activities.
If you have a washdown pad in place, make sure that customers know the best management practices and rules associated with its use. Check filters and other systems often, and ensure your employees know how to operate and detect problems with any water treatment system in place.
Having a washdown pad means you're required to have a system in place (and permitted) for dealing with pressure wash water. Options include:
- Closed loop systems that collect, treat and reuse pressure wash water.
- Collect pressure wash water, treat it and discharge to the municipal sanitary sewer.
- Collect pressure wash water into a holding or settling tank for treatment. If the wastewater doesn’t contain chemical additives, it may be diverted into wet-pond detention basins, vegetated buffers or swales.
If unable to dispose of wash water in the above ways, make sure to treat any water that is discharged. There are regulatory permits that are triggered by this activity. Make sure to review them and your compliance. LINK TO APDES DISCHARGE PERMIT.
Best practices for boat washing
- Deciding which products to use and how to wash a boat can be overwhelming with the number of products and suggestions on the market. Here are some tips that you can share with customers. Print out this sheet of best practices.
- Use ‘elbow grease’ and plain water whenever possible. Don’t jump to chemicals for cleaning unless necessary for the job at hand.
- Shopping tips to minimize use of toxic cleaners:
- The words on labels have meanings! Look for the following “Signal Words” and try to buy a less hazardous product.
- DANGER – extremely flammable, corrosive, or toxic
- WARNING – moderately hazardous
- CAUTION – Less hazardous
- Look for third party certifications for less-harmful products. These include the EPA-certified “Design for the Environment” label or Green Seal Certified products. You can search for products and manufacturers on their websites.
- Read labels and avoid these ingredients: ammonia, sodium hypochlorite, chlorine, petroleum products or lye.
- Follow directions on the label! It is very common to use more product than is necessary for cleaning jobs. Avoid wasting money and creating toxic waste streams by diluting and using products as they are designed. Read labels and make sure your crew knows how to properly use the products on-board as well.
- No bilge cleaner on the market “eats” fuels and oils! While they do disperse, they are still in the wash water and the result may be more toxic to the environment. Get fuels and oils out of your bilge using absorbents as much as possible. See our page on bilge care for more.
- Use alternative cleaners whenever possible! See this chart for some ideas of what you can use.
- Wash boats on a level and permeable surface (i.e. lawn, crushed stone or sand) so that the wash water can infiltrate into the ground ifthere is no drinking water well on the property or downstream that would be impacted.
- Place filter fabric over the permeable surface before washing to collect solids and sediments for proper disposal.
- Never allow boat washing on or near load and launch ramps. This ensures wash water will end up in the harbor basin, along with any paint chips, sediments or other materials that could negatively impact marine life.
QUESTIONS: Does your facility have a dedicate washdown pad? Do harbor staff pro-actively communicate good boat washing practices to customers?