2012 Ocean Ranger Guidebook Revision 3-7-12 - Alaska ...

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2012 Ocean Ranger Guidebook 3-7-12 higher than 50 μg/L. You must record the location of the discharge, the estimated volume of the discharge, and the concentration of chlorine or bromine (as applicable). Records of this monitoring must be kept with other graywater monitoring records. For chlorine, analytical results below the method detection limit shall be deemed compliant with the effluent limits, provided the permittee uses a testing method with a detection limit no higher than 10.0 μg/L under ideal conditions. EPA recommends method SM4500-CL G (DPD Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal conditions and so meets these requirements. SM4500-Cl G is typically the method that ADEC/USCG uses for compliance monitoring. For bromine, analytical results below the method detection limit shall be deemed compliant with the effluent limits, provided the permittee uses a testing method with a detection limit no higher than 50.0 μg/L. Job Aid Item: 1.2.m Text: Deck wash down / hull cleaning (above Waterline); Minimize debris and residues/ minimize paint, rust and materials entering water during maintenance and use non toxic cleaners (EPA VGP 2.2.1). What to check for: Monitor exterior cleaning and maintenance operations when feasible. Check for safeguards to prevent oily wastes, paints, and debris from entering waters. These must be minimized, but the EPA defines as “reduce and/or eliminate to the extent achievable using control measures (including best management practices) that are technologically available and economically practicable and achievable in light of best marine practice.” Check for foamy discharge, sheens, and floating waste from runoff or deck wash. Check for large pieces of rust, paint, metal, etc. being washed or dropped over the side. Check for tarp covers, paint can controls, debris collection, rust capture controls. Non-toxic and “phosphate free” (below 0.5% phosphates) cleaners are to be used if water is discharged within 3nm of shore. Unused paint cannot be discharged into water. Check on products used. Figure 16-Example of painting with drop cloth protection Background: Maintenance and cleaning activities could introduce oils, grease, paints, toxic chemicals, or solid wastes into the water. Sheens have been observed from painting activities in the past. There is a also a long term concern about paint chips and other wastes accumulating in large quantities and leaching out toxins. Most operators have been careful about hull maintenance, deck maintenance, and painting operations. For example, using tarps under painting activities should reduce dripped paint entering seawater. 24
2012 Ocean Ranger Guidebook 3-7-12 The methods and products used for deck cleaning vary. In particular the teak decks and wood composite decks are cleaned with special cleaners. It would be useful to check these products. Most vessels do not perform painting operations in SE Alaska. Most is this related to the weather conditions (rain). However, it appears that some operators do touch up painting on vessels, in particular the outside hull scantlings which are in direct sight. Mostly these operations are performed in Skagway and Juneau. Good indicators are the cherry pickers on the docks. Citation: EPA VGP 2.2.1 Deck Washdown and Runoff and Above Water Line Hull Cleaning Vessel owner/operators must minimize the introduction of on-deck debris, garbage, residue and spill into deck washdown and runoff discharges. When required by their class societies (e.g., oil tankers), their flag Administrations, or the U.S. Coast Guard, vessels must be fitted with and use perimeter spill rails and scuppers to collect the runoff for treatment. Where feasible, machinery on deck must have coamings or drip pans to collect any oily water from machinery and prevent spills. The drip pans must be drained to a waste container for proper disposal and/or periodically wiped and cleaned. The presence of floating solids, visible foam, halogenated phenol compounds, and dispersants, or surfactants in deck washdowns must be minimized. Vessel operators must minimize deck washdowns while in port. Vessel operators must maintain their topside surface and other above water line portions of the vessel to minimize the discharge of rust (and other corrosion by-products), cleaning compounds, paint chips, non-skid material fragments, and other materials associated with exterior topside surface preservation. Furthermore, vessel owner/operators must minimize residual paint droplets from entering waters subject to this permit whenever they are conducting maintenance painting. Possible minimization techniques include, but are not limited to, avoiding paint spraying in windy conditions or avoiding overapplication of paint. This permit does not authorize the disposal of unused paint into waters subject to this permit. If deck washdowns or above water line hull cleaning will result in a discharge, they must be conducted with non-toxic and phosphate free cleaners and detergents. Furthermore, cleaners and detergents should not be caustic or only minimally caustic and should be biodegradable. Section 1: Subsection 3: Discharge vessels general Job Aid Item: 1.3.a Text: Approved Vessel Specific Sampling Plan onboard, up-to-date and available (AS 18AAC 69.025(f) / 33 CFR 157.317(b/General Permit) What to check for: The VSSP is carried onboard and is available. The VSSP should be checked in the seasonal report. For regular checks, check the VSSP if changes have been made- for example to tanks used, or types of WW treated. Background: The purpose of the VSSP is to explain how samples are taken so they are representative of typical wastewater treatment process. Inaccuracies have been found in VSSPs, often when changes are made onboard. The VSSP needs to be available as a reference. A copy of a sample VSSP is included as wastewater example 2. Citations: 25
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