The federal Clean Water Act sets forth standards for wastewater discharges. The Environmental Protection Agency (EPA) charges individual states with enforcing the law, which varies widely from state to state.
Overall, compliance standards are becoming tougher, and many states are more stringently enforcing environmental laws. States that currently don’t have rigorous wastewater standards can expect to see them in the coming years. Even if the government isn’t currently forcing marinas in certain areas to meet stricter standards, they can still prepare now for the future. And making powerwash operations more green have other benefits to help marina business.
The Clean Water Act regulates many contaminants. A 2007 study by the North Carolina Division of Water Quality found that typical boat wash wastewater contains 69,000 times more copper than the Federal Clean Water Act allows for discharge.
In particular, environmental compliance authorities have growing concern that some wastewater recycling systems do not remove heavy-metal concentrations to environmentally safe levels. These agencies have observed that a significant quantity of high-pressure powerwash wastewater drifts onto surrounding property and waterways.
Consider these important questions:
- Does the marina have a recycling system that is designed to remove heavy metals to the extent necessary for easy compliance?
- What would the facility estimate the additional labor costs would be if staff had to secure a spray barrier around each boat hauled?
- If current state standards aren’t in place, how long will it be before the state’s compliance officers issue similar standards?A marina or boatyard shopping for a powerwash recycle system should make sure the system has been designed and manufactured in anticipation of the toughest compliance standards and can be easily permitted by compliance authorities.
In addition to keeping marinas in compliance with environmental regulations, installing an effective recycling system can also bring additional benefits to the business. Consider the following reasons why marinas should make sure they comply with the strictest wastewater standards.
Protect property value
Most lending institutions require environmental audits for boatyard and marina financing. Just like a termite inspection on a home, banks want to ensure that a property has a clean bill of health and will not incur very high environmental remediation costs.
An EPA audit of an Oregon boatyard led the agency to declare the yard a toxic waste site. Agents seized evidence of environmental crimes, including records and soil samples. EPA arrested, fined, and then sued the owner and the previous two owners of the boatyard to help cover the millions of taxpayer dollars spent removing toxins from the property. The owner pleaded guilty in 2004 in U.S. District Court to a felony violation of the Clean Water Act.
Once dry, heavy metals are encapsulated in the sludge, it typically is classified as non-hazardous and can be disposed of with other marina trash.
Improved environmental testing
While some locations allow a certain grace period for environmental compliance, government authorities will often require a facility to hire a certified chemistry lab to periodically submit stormwater runoff test results. Many states require these tests every six months, and if toxic discharge target levels are elevated they often step up the testing intervals and mandate improvement. And the tests are not cheap.
Jim Frei, an environmental consultant at Stormwater Services Group, LLC, said, “The lab analysis fee will be about $135. The labor (sample prep/watching weather), materials and reporting cost will be about $350-$500 depending on travel time to site for a consultant to do the in-field sample collection. Of course, if marina staff performs the sample collection and report writing, it will cost less. The reason the labor cost is high for a consultant is the sample (in North Carolina and some other states) has to be collected within 30 minutes after discharge, so the collector has to be at the site before rain starts.”
Improved relations with compliance authorities
With better environmental tests and a commitment to wastewater standards, marinas can be seen as marine industry leaders in green practices, which can improve relations with compliance authorities. In addition to showing those in charge of wastewater standards that the marina takes environmental responsibility seriously, these green practices can help in dealing with regulators in many areas of the business.
For example, marinas might have a better chance of obtaining approvals to dredge or renovate, especially if it involves environmental concerns, if the facility can show other ways in which it protects the environment, such as its commitment to green powerwash operations.
Many media outlets feature companies that adopt new green and clean practices that positively impact the environment. If a marina grabs a vanguard position in environmental compliance, its initiatives will likely be publicized in local, state and possibly, the national press.
Increased market share
Consumers are increasingly green conscious. Market research reveals that the environmental friendliness of products and services play key roles in purchase decisions.
Avoid the thin ice
Does a non-compliant powerwash operation put a marina on thin ice? YES, especially if a nearby competitor has taken the plunge and invested the necessary capital to bring its powerwashing into compliance. A non-compliant marina that wants to compete with a compliant facility may do so by offering lower cost haul-out and powerwash services. What is the possibility then that the compliant owner will call to complain to regulatory officers and/or the media about illegal discharges?
The compliant owner will be able to make a very good case that a non-compliant marina is unfairly undercutting its rates.
How will compliance officers react to the complaint? How would the media respond? Do marinas want to risk the possible negative publicity?
Positive cash flow
If marinas go clean and green, they can attain a positive return on their compliance investment.
The approximate cost to have wastewater hauled off-site in North Carolina was more than $0.60 per gallon in the fall of 2010. Higher fuel costs will send this rate even higher. While the quantity of powerwash wastewater generated will vary greatly from marina to marina, a North Carolina Sea Grant study estimated that the average N.C. yard would generate approximately 11,000 gallons of wastewater annually. At $0.60 per gallon, average annual hauling fees would be about $6,000.
Some yards charge customers a fee for each gallon of wastewater generated. Assuming that yards pass along the $0.60 per gallon disposal charge to their customers for disposing of the waste, a price benchmark estimate can be used to determine if revenue can be generated from treating and recycling boat wash wastewater.
Supply costs for recycling systems vary, but most are measured in pennies for gallons. With a $0.02 supply cost per gallon, the annual average supply cost for a recycle system would be approximately $220.
Some systems are so easy to use that labor costs to operate the system are not significantly greater than the costs to collect, pump and store wastewater for haul-off.
Clean Marine Solutions, a North Carolina manufacturer of wastewater recycle systems, projects that a marina can generate almost $5,000 in profit annually, if it charges boaters the same $0.60 per gallon rate.
A North Carolina boatyard owner recently estimated it cost about $3,500 to haul, paint, change zincs and cutless bearings, and launch a 45-foot sport fishing boat. A boat of this size will generate on average about 125 gallons of wastewater, making the environmental surcharge fee about $75 or 2 percent of the overall fee.
This surcharge fee would effectively be equivalent to the 2 percent surcharge many states mandate for the disposal of tires and batteries. (The surcharge is typically based on the cost of the new item).
The advantages of going clean and green now are great. For more information about solving powerwash compliance issues and wastewater treatment and recycle systems, contact us.