As a harbor facility, there are a number of ways you can reduce your stormwater impacts, including best practices to minimize runoff, reduce pollutants in your runoff (source control), and ways to treat your stormwater runoff. In this section we also have resources on permitting, Stormwater Pollution Prevention Plans (SWPPP) and how your facility can develop and implement an effective SWPPP if you run a boatyard.
An important legal note
Check with the Alaska Department of Environmental Conservation to determine if your facility should have a permit to discharge industrial stormwater (note that this is different from construction stormwater permits). As a marina, your small boat harbor is a regulated industry. At a minimum, you must submit a Certificate of No Exposure to ADEC. This tells ADEC that you know you are a regulated industry, but that you don’t have ongoing activities at your facility that require permitting. If you operate an uplands boatyard, you are required to have a stormwater permit which requires a Stormwater Pollution Prevention Plan (SWPPP). We’ll talk more about SWPPS in this section so you are familiar with what goes into one and how they are used.
Also note that water from pressure washing and wash-down pads is NOT considered stormwater and is covered under a different permit. See our resources on Boat Maintenance for more on this topic.
At your facility, do you have vegetative buffers (for example, strips of grass) between parking lots and the water?
When you start construction projects, do you work on designs to minimize impervious areas?
Do you work to protect and expand where possible vegetative buffers to reduce runoff?
If you have storm drains, are they stenciled or otherwise labeled to tell the public they drain to the harbor or other waterbody?
Do you have prevention measures in place to protect against discharges from floor drains and sumps in your facility buildings?
Does your facility have either a Certificate of No Exposure OR a Multi-Sector General Permit?
It rains in Alaska. Even in drier regions, the rains come and wash across our parking lots and other uplands. The first step in addressing stormwater pollution is reducing the amount of oils, metals, and other debris exposed to rainwater.
There is a huge variety of best practices that you and your customers can implement to reduce pollutants in stormwater runoff.
Stencil stormdrains to let everyone know the drain leads directly to waterbodies. This can be done with paint stencils, plastic or metal decals.
Make sure that all construction projects in the uplands utilize control measures to reduce runoff of sediment and any other potential pollutants. Construction projects greater than one acre in size are required to have their own separate stormwater permit and accompanying SWPPP.
Protect storm drains with filters and/or oil-grit separators.
Prevent polluting discharges from floor drains and sumps. Floor drains must be sealed and not used unless the drain is connected to a municipal sewer, or a holding tank for treatment before discharge. Install oil-grit separators at your floor drains to remove free-floating oils and grease. Seal your floor drains with a cover if you are working on a large project or anything with the potential to spill.
Water runs fast down pavement, hard dirt, and other “impervious” surfaces. (NOTE- Pop-up box to define impervious) Your facility may have a number of options to slow down and minimize the runoff into your harbor basin and other surrounding waters.
Vegetative buffers are a great way to slow down and minimize stormwater runoff. If you have strips of grass or other vegetation between your parking lots and harbor, make sure you maintain and preserve those areas.
During the design of new projects, work with your engineers to maintain, expand or develop vegetative buffers wherever possible to reduce runoff into your harbor basin and other waters.
Minimize the amount of impervious cover as much as possible. Consider porous materials such as gravel for parking lots and lightly traveled roads. Talk with your engineers during design of new projects and upgrades to ensure they are thinking about the reduction of impervious surfaces at your facility.
Once your facility has taken measures to reduce runoff and minimize pollutants, its now time to look at what treatment may be necessary for the runoff before it hits the water. There are a number of options, ranging in cost, design need, space and maintenance. We’ll review a number of options here, but make sure to talk with other facilities around the state, your City/Borough public works department, your engineering firm, and other facilities in Washington and other states where they’ve been working with stormwater treatment solutions for years.
Stormwater treatment is either done through active or passive systems - ones that require electricity vs. ones that don’t. Active treatment systems include chemical filtration, chemical treatment, electrocoagulation, filtration, ion exchange and reverse osmosis. Passive treatment systems include bioretention/filtration, drain inlet insert, hydrodynamic separation, media filtration, and oil/water separators. Installing infiltration trenches and rain gardens around your facility are examples of passive systems that you may be able to use at your facility to treat minimally polluted stormwater without huge expense.
Stormwater Treatment resources
The Washington Dept. of Ecology commissioned a report in 2011 on Treatment Technologies for Industrial Stormwater that further discusses all of these options. This is a large document, and more information, download and use this as a great reference! It includes estimates of specs, costs, and effectiveness for dozens of active and passive treatment options.
You are probably familiar with the term SWPPP. Construction projects over an acre in size are required to have them under the Construction General Permit. Specific industries have stormwater permit requirements as well. Marinas and boatyards are covered under the Multi-Sector General Permit for stormwater runoff. But what is a SWPPP and how do you go about developing one if you need it?
Your MSGP Stormwater Pollution Prevention Plan (SWPPP) is a document that tells harbor employees, customers, the public and the state regulatory agency the following things:
- What kinds of activities have the potential to produce pollution
- How is your site laid out and where does rainwater flow and discharge
- What measures do you take to reduce pollutants in rainwater through minimizing exposure, good housekeeping, maintenance, spill prevention and response, and erosion and sediment controls
- How do you treat rainwater to remove pollutants before discharge
- How do you inspect and monitor your activities and discharge for compliance
- How are employees trained on pollution prevention and SWPPP implementation
Working with your customers and your community to develop best practices for boat and hull maintenance activities at your facility is a huge step towards an effective SWPPP - see the section on boat maintenance for more ideas and suggestions. In the state of Alaska, the SWPPP does not need to be signed by a Professional Engineer. Your SWPPP does need to be a living document that harbor staff understand and can easily reference and use.
At the AAHPA conference in Wrangell, Harbormaster Greg Meissner talked candidly about the development of the SWPPP for their marine industrial center. They had hired out the task to an engineering firm, and the document they got was not something Greg felt his people could actually use. He sat down, figured it wasn’t rocket science, and essentially re-wrote the thing to be a document that made sense to meet the needs at his facility. At Alaska Clean Harbors, we’re hoping to help facilities save money and develop SWPPPs that are understandable and usable.
The EPA developed a great resource for industrial operators developing a SWPPP: Developing Your Stormwater Pollution Prevention Plan - A Guide for Industrial Operators (2009)
The companion document is also very helpful: Industrial Stormwater Monitoring and Sampling Guide (2009)
For more on the Alaska MSGP and SWPPP, see the ADEC website.
Contact Alaska Clean Harbors for more information and help with your SWPPP!