_____________________________________________

Stormwater Pollution Prevention Plan

(SWPPP)

_____________________________________________

Rev. August 2016

Certification

Certification by Responsible Company Official: I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system design to assure that qualified personnel properly gathered and evaluated the information. Based on my inquiry of the person or persons who manage the systems or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Name: Michael Nelson Title: Vice President

Signature:

Date: August 30, 2016

.

Table of Contents

1. Pollution Prevention Team 2. Facility Assessment 3. Monitoring Plan 4. Best Management Practices 5. References 6. Modification History

1. Pollution Prevention Team

The Pollution Prevention Team (PPT) for this facility is comprised of company owners, project managers, crew supervisors and leads, human resources staff, and environmental staff. Employee positions that comprise the facility’s stormwater pollution prevention team and their responsibilities are listed below.

Title Name SWPPP Responsibilities

Owners and Management Team

Dick Nelson

Mike Nelson

Rick Kirschman

Nancy Loftis

Ultimate responsibility for environmental compliance, reporting, and support. Implements environmental policies, procedures, and BMPs. Signs DMRs. Directs corrective action where required. Leads company’s Environmental Management System (EMS) program.

New Construction Manager

Rick Kirschman

Implements environmental policies, procedures and BMPs. Trains supervisors and leads on BMPs. Implements corrective action where required.

Repair Manager Ron Daniel Implements environmental policies, procedures and BMPs. Trains supervisors and leads on BMPs. Implements corrective action where required.

Yard Supervisor Tony Junkman Implements and follows environmental policies, procedures and BMPs. Trains supervisors and leads on BMPs. Implements corrective action where required.

Human Resources Lynne Voorhees Provides initial training orientation on environmental policies, procedures, and BMPs. Maintains environmental training plan and records for all employees.

Maintenance Mechanic Supervisor Jeff Jensen

Follows environmental policies, procedures and BMPs. Implements corrective action where required.

Environmental Compliance Manager Marie Piper

Develops environmental policies and procedures for management approval and implementation. Conducts environmental sampling and monitoring. Conducts monthly inspections. Prepares SWPPP and BMP updates for management approval and implementation. Coordinates HAZWOPER training and refreshers for Environmental & Hazardous Waste Specialists. Suggests corrective action where required.

Environmental & Hazardous Waste Specialists

Gary Meagher

Matt Dawson

Dan Curtis

Follows environmental policies, procedures and BMPs specific to their work area. Assists with spill response and cleanup. Manages hazardous waste storage area (DW-1) and water treatment facilities. Conducts storm drain inspections and maintenance.

Other Crew Supervisors and Leads (see below)

Varies Follows environmental policies, procedures and BMPs specific to their work area. Implements corrective action where required.

Non-Environmental Hazardous Waste Handling and Key Environmental Training Positions Painting Supervisor / Lead – Employees in this position are in charge of planning, directing, and organizing the activities of the Paint Crew. Painting Supervisors also mix paint, sand blast, and operate man lift equipment. Painter - Employees in this position are responsible for preparing metal surfaces for painting and painting parts, equipment, interiors and exteriors of ships, boats and shipyard buildings, using brushes, spray guns, and rollers. Painters also mix paint, sand blast, and operate man lift equipment. Painter Helper / Laborer - Employees in this position are responsible for cleaning and preparing for painting interiors and exteriors of ships, boats and shipyard buildings. Lead Maintenance Mechanic and Maintenance Mechanic - Employees in this position repair and maintain, in accordance with diagrams, sketches, operation manuals and manufacturer’s specifications, machinery and mechanical equipment, such as engines, motors, pneumatic tools, drill presses, pressure washers, forklifts, cranes, man lifts, scissor lifts, and production machines and equipment, using hand tools, power tools, and precision-measuring and testing instruments. Operator Supervisor and Operator / Truck Driver - Employees in this position operate forklifts, fork trucks, man lifts, carrydecks, cranes, fuel trucks, and other mobile equipment to move, locate, relocate, and stack materials. The Operator may be involved with fueling of equipment. The Operator is accountable for the safe and efficient operation of the equipment and for the immediate cleanup of any spills or leaks from using or fueling the equipment. Machinist Supervisor / Lead - Employees in this position supervise and perform fabrication, repair, and modification of metallic and nonmetallic parts. They operate lathes, milling machines, and other machine shop equipment. Machinist - Employees in this position perform fabrication, repair, and modification of metallic and nonmetallic parts. They operate lathes, milling machines, and other machine shop equipment.

Repair Supervisor / Lead - Employees in this position supervise and perform fabrication, repair, and modification of vessel structures and parts. They coordinate repair work with other crews. Hydraulic Systems Lead and Sea Trial & Start Up Lead – Employees in this position lays out, installs, flushes, and pressure tests hydraulic and pneumatic piping systems for cranes, winches, davits, steering, or any component on a vessel that requires hydraulics or pneumatics for its operation, following blueprints, and using hand tools and shop machines. Employees in this position coordinate and execute procedures for startup, testing, and trials of new construction vessels. Hydraulic Systems and Sea Trial & Start Up Assistant - Employees in this position assist with lays out, installs, flushes, and pressure tests hydraulic and pneumatic piping systems for cranes, winches, davits, steering, or any component on a vessel that requires hydraulics or pneumatics for its operation, following blueprints, and using hand tools and shop machines. Employees in this position assist with coordination and execution of procedures for startup, testing, and trials of new construction vessels.

1.1 Environmental Management System (EMS)

This SWPPP is an important feature within DCI’s Environmental Management System program.

2. Facility Assessment

2.1 Facility Description

Dakota Creek Industries, Inc. (DCI) conducts Ship Building and Repairing (Standard Industrial Code No. 3731).

Activities at the facility include:

Pressure washing and Hydro-blasting of vessel hulls and structures

Bottom and top side painting

Engine, prop, shaft, and rudder repair

Hull and structure welding and grinding

Hull and structure repair, joinery, and bilge cleaning

Fuel and lubrication systems repair and replacement

Abrasive blasting

Other activities necessary to maintain or construct a vessel

History

DCI is a ship construction and repair facility located on Guemes Channel in Anacortes, Washington. Operations are conducted on four acres of private land and approximately ten acres of the Port of Anacortes Marine Terminal. The site has supported water-dependent uses since approximately 1890.

2.2 Site Map

2.3 Identification of Industrial Activity Areas

DCI provides service to a wide variety of ship types, predominantly with steel hulls. Approximately 25 vessels are repaired in a typical year and another 2 or 3 are built. Ship repair services provided by DCI include engine and propulsion repair as well as hull maintenance. Activities at the shipyard include machining, steel fabrication, painting, welding, electrical, pipe fitting, abrasive blasting, carpentry, facility and equipment maintenance, and pressure washing. There are no storm drains in any building at DCI.

Drydock: 312 feet x 90 feet, 9000 tons

DCI has a floating drydock that is moored at the Port of Anacortes Pier #1 and has been in service since February 1994. The shipyard uses the drydock to repair ships and to clean, and paint ships’ bottoms, propellers, rudders and external parts below the water line. It also uses the drydock to construct new ships. Many of the vessels hauled out require pressure washing.

The drydock is fully able to contain pressure wash wastewater. A pressure wash wastewater collection trough is located on the east side of the drydock and a removable collection sump is located on the southeast corner of the drydock. A significant amount of sludge accumulates in the sump. Before the drydock is lowered, the collection sump is removed and hoisted ashore where it is routinely cleaned. Syncrolift: 306 feet x 75 feet, 5000 tons The Syncrolift provides a mechanism for hauling ships out of the water for transferring onto shore for repair work. Repairs are not conducted over the water; the transfer rails are located in a paved area of the yard just on shore and provide containment for pressure wash waste water. The Syncrolift is also used to launch newly constructed vessels. The Syncrolift and its transfer rails are located just east of Pier #1. Wastewater treatment processes and discharge locations: OUTFALL 001 (48.522230°, -122.610590°) Treated Stormwater to Guemes Channel Stormwater, under previous permit, either infiltrated into the ground, sheet flowed into Guemes Channel, or passed through oil separating catch basins before joining the City storm drain system which discharged to Guemes Channel. In 2008, DCI contracted with an engineering firm to develop an Engineering Report for Stormwater Treatment as part of the Port of Anacortes and DCI redevelopment project. During the redevelopment project, storm drains were installed throughout the shipyard for stormwater to be conveyed to a stormwater collection sump for treatment prior to discharge to Guemes Channel. In 2009, DCI

installed a StormwaterRx Aquip filtration system to service the storm drains from the shipyard. Several catch basins are located throughout the facility that collect stormwater and treat it prior to discharging to Guemes Channel. The deeper ones have fabric drain guard inserts to catch sediment and to absorb residual oil, grease, and other hydrocarbons. The drain guards also provide another layer of protection in the event of spill. The stormwater is conveyed to the StormwaterRx Aquip treatment system. The system consists of a stormwater storage tank and the Aquip enhanced media filtration tank with a buffering pre-treatment chamber and an inert and sorptive filtration media chamber. The StormwaterRx treatment system targets reducing suspended solids, turbidity, heavy metals (including dissolved metals), and organics. Sampling for Outfall 001 takes place at the outlet of the Aquip treatment system. The discharge from the Aquip treatment system enters an 8” diameter pipe that connects to a 36” diameter pipe that discharges into Guemes Channel via a Tideflex valve. DCI does not discharge bypass stormwater. Overflow from excessive storm events is routed back to the in-ground sump cycling back to the Aquip treatment system.

Figure 1. Stormwater treatment process prior to discharge from Outfall 001

OUTFALL 002 (48.522170°, -122.611210°) Drydock floodwater to Guemes Channel Drydock floodwater is discharged when the drydock is flooded to dock or float a vessel onto or off the drydock floor. When the drydock floor submerges, there is a potential for pollutants to enter Guemes Channel if the drydock floor has not been cleaned of debris and pollutants which landed on the drydock floor during vessel repair activities. Prior to every lowering of the drydock, the deck and stairwells are thoroughly swept and cleaned of any debris. When time allows or conditions mandate, the deck and stairwells are pressure washed with the pressure wash water collected and sent for treatment. If any oily substance landed on the drydock deck during any work, the spill is immediately cleaned and the collection trough and sump are thoroughly cleaned to ensure no oily residue is remaining that could cause sheen on the water during the flooding of the drydock. Before every lowering of the drydock, an inspection is made and photographs depicting the cleanliness of the drydock deck are taken and logged. Sampling for Outfall 002 is done from the catwalk above the southeast corner of the drydock.

Figure 2. Stormwater treatment process prior to discharge from Outfall 002

OUTFALL 003 (48.519710°, -122609720°) Wastewater and process water to the City of Anacortes WWTP Pressure wash wastewater and other wastewater and liquids are collected and transferred to the ElectroPulse electrocoagulation unit (ECU) for treatment before discharging to the City of Anacortes sanitary sewer system. Wastewater contaminants such as suspended solids and heavy metals pass by the energized ECU plates and take on positive and negative charges causing the tiny particles to bond together like miniature magnets. The contaminants are then removed from the clear phase of the water and transferred to a sludge accumulation tank for proper disposal off site. The clear water is discharged to the sanitary sewer system. Sampling for Outfall 003 is done at the discharge point from the ECU system. Wastewaters can include pressure wash and hydro blast wash water, engine treatment water, potable water tank treatment and test water, tank preparation and test liquids, grey water, ballast water, non-petroleum based industrial coolants, sludge water from cleaning of holds and sumps, flooring wash water, fire system test water, etc. Wastewater and liquids are contained via a trough and sump on the east end of the drydock, via troughs and a sump that serves the rails area, and via another sump that serves the mechanics shop wash pad. Waste liquids from the drydock and rails area sumps are transported by tank truck to treatment prior to discharge to the sanitary sewer system. Some wastewater and waste liquids are contained in totes directly from ship’s holds or engines or other equipment and transferred by fork truck to treatment prior to discharge to the sanitary sewer system. Wastewater treatment from the mechanics wash pad also includes a Model SM2 Ultrasorb System in line before the ECU system. The SM2 system comprises of an accumulation tank with oil skimmer and coalescers, coalescing centrifugal separator, hydrocarbon absorber, and polishing filters to remove oil and VOCs from the wastewater. The backup plan for the ECU treatment and SM2 treatment systems is to have the waste liquids hauled and disposed offsite by licensed contractors.

Figure 3. Treatment process prior to discharge from Outfall 003

Solid wastes Waste abrasive blasting grit is stored in a fully enclosed tent structure prior to being sent offsite for reuse in the manufacture of cement. The blasting tent is also used to contain blasting dust when blasting parts. The other primary areas where abrasive blasting is conducted are the drydock and the headwall/rails area. On the drydock, waste grit is recovered with brooms, shovels, and small front-end loaders. A final wash down of the drydock floor conveys any remaining grit to the collection sump. Brooms, shovels, and front-end loaders are also used to recover waste grit on the headwall/rails area. Dangerous waste Used oil, grease, spent solvent, waste paint, antifreeze, universal waste, scrap metal, and other solid and hazardous waste is handled, stored, and recycled or disposed offsite in accordance with Washington State Dangerous Waste requirements, minimizing their potential to impact water quality.

Sludge Sludge from sumps and ships’ holds is dewatered to a practical extent and then recycled or disposed offsite by licensed contractors. Oily waste Oily waste water is typically found or generated during vessel bilge cleaning and fuel tank cleaning. Oily water is contained and stored for recycling and disposal offsite by licensed contractors. Solvents, paint and hazardous waste Spent solvent, waste paint, and other hazardous wastes are handled, stored, and recycled or disposed offsite by licensed contractors in accordance with Washington State Dangerous Waste requirements. Recyclables Recyclables, including scrap metals, wood, paper, cardboard, Universal Waste (such as used oil and grease, used oil filters, spent antifreeze, batteries, and fluorescent bulbs), and used zinc anodes are recycled offsite by licensed contractors. Sanitary waste Sanitary waste (black water) is collected and transported offsite to a sanitary sewer system. Other solid waste Other solid waste such as office waste and other municipal waste is collected and stored in containers while awaiting transport to the local transfer station.

2.4 Material List

This section includes an inventory of materials handled on the site that may have the potential to be exposed and contribute pollutants to stormwater, an assessment of potential pollutants associated with those materials, and an explanation of how significant materials are managed to prevent pollution of stormwater.

Material Potential Pollutants

Associated BMP Number(s)

Significant Spill History (within last 5 years)

Blasting Grit Metals 2, 3, 4, 7, 10 None

Pressure Wash Water

Metals 2, 6, 7, 8, 9, 10 None

Raw materials such as galvanized pipe, steel, aluminum

Metals 2, 3, 10 None

Paint Debris Metals 1, 3, 4, 7, 8, 10 None

Paints Metals 1, 3, 5, 7, 8, 10 05/29/2013 – Pressurized spray hose burst with less than a pint of paint spilled into the Guemes Channel.

Solvents Volatile Organic Compounds

1, 3, 7, 8, 10 None

Fuels and Lubricants

Oil & Grease 1, 3, 7, 8, 9, 10 01/23/2015 - Hydraulic hose on air compressor burst with less than a quart of hydraulic oil spilled to Guemes Channel. Compressor fan blew oil droplets to channel before machine could be shut down.

Process Waste Water

Metals, Oils 1, 3, 7, 8, 9, 10 None

Sludge Metals 1, 3, 7, 8, 10 None

Solid Waste Metals, Oils 1, 2, 3, 7, 8, 10 None

3. Monitoring Plan

Sampling of stormwater discharges is conducted twice each month of each year for some parameters and quarterly for others. A visual observation of the presence of oil sheen is conducted each time the deck of the dry dock is submerged. Sampling of the water for oil and grease during a dry dock submerging occurs quarterly. Sampling of the pressure wash/process water discharge to the sanitary sewer is conducted quarterly, at a minimum.

Monitoring records are to be retained on site for a minimum of five years.

Sampling of each type of discharge is discussed in the following sections. Samples and measurements taken must represent the volume and nature of the monitored parameters, including representative sampling of any unusual discharge or discharge condition, including bypasses, upsets, and maintenance-related conditions affecting effluent quality.

Sampling and analytical methods must conform to the latest revision of the Guidelines Establishing Test Procedures for the Analysis of Pollutants contained in 40 CFR Part 136 (or as applicable in 40 CFR subchapters N [Parts 400–471] or O [Parts 501-503]) unless otherwise specified by Ecology. Ecology may only specify alternative methods for parameters without limits and for those parameters without an EPA approved test method in 40 CFR Part 136.

The Environmental Compliance Manager is responsible for conducting stormwater, dry dock, and pressure wash/process water sampling. The dry dock operator is responsible for logging the visual observation of oil sheen during each dry dock submerging.

3.1 Stormwater Sampling Locations and Schedule

Discharges to surface waters will be monitored in accordance with the following list of designated sampling locations and the monitoring schedule.

The following designated sampling locations will be monitored (as indicated on Site Map):

1. Outfall 001 is sampled at the exit of the Aquip treatment system.

2. Background is sampled at the end of the East Pier (new pier).

3. Outfall 002 is described below and Outfall 003 is at the outlet of the electrocoagulation unit(s).

If stormwater discharges do not occur during the sampling period, then “no discharge” will be indicated on the Discharge Monitoring Report (DMR). Sampling results will be reported to Ecology on an electronic DMR as required by the permit.

Monitoring Schedule for discharges from Outfall 001 (Stormwater from facility to Guemes Channel)

Parameter Units Sample Point a Minimum Sampling Frequency Sample Type

Copper, Total µg/L Outfall 001 Twice per month c Grab b

Nickel, Total µg/L Outfall 001 Once per Quarter Grab b

Zinc, Total µg/L Outfall 001 Once per Quarter Grab b Turbidity NTU Outfall 001 Twice per month c Grab b Oil and Grease mg/L Outfall 001 Twice per month c Grab b a Samples must be collected from the Outfall 001 or from an on-line stormwater drain

access point nearest the Outfall terminus. b Grab means an individual sample collected over a fifteen (15)-minute, or less, period. c Minimum of 72 hours’ time gap between two consecutive samples.

Monitoring Schedule for Outfall 002 (Drydock water to Guemes Channel)

Parameter Units Sample Point

Minimum Sampling

Frequency

Sample Type

Drydock Receiving Water

Oil and Grease mg/L Drydock Quarterly Grab

Drydock Receiving Water

Oil and Grease (Oily sheen)

Yes or No Drydock Each launch Visual Observation b

a Grab samples must be collected from the outboard apron area of the drydock after the initial submergence following hull repair activities and when there is at least three feet and less than six feet of water over the floor apron. Samples will be considered invalid if taken after the 6-foot water level is reached. If no undocking occurs in a given quarter, this must be clearly stated on the Discharge Monitoring Report.

b A file containing a log of observations for visible sheen must be maintained. If there are any night launches, the log will identify when observations are not possible.

Monitoring Schedule for Outfall 003, Sanitary Sewer (Process Water to the City of Anacortes WWTP)

Parameter Units Sample Point Minimum Sampling

Frequency

Sample Type

Flow Gallons per day a

Point of discharge to Anacortes WWTP

Quarterly Meter

Copper, Total µg/L Point of discharge to Anacortes WWTP

Quarterly Grab Lead, Total µg/L Point of discharge to Anacortes

WWTP Quarterly Grab

Zinc, Total µg/L Point of discharge to Anacortes WWTP

Quarterly Grab Nickel, Total µg/L Point of discharge to Anacortes

WWTP Quarterly Grab

a Calculated by dividing quarterly water usage with number of days.

Stormwater Monitoring Summary

Category Parameter Units Sample Point

Minimum Sampling

Frequency

Sample Type

Stormwater (001)

Oil and Grease mg/L Aquip

Treatment Outlet

Twice Monthly Grab Total Recoverable

Copper, Zinc, Nickel mg/L

Turbidity NTU

Background Turbidity NTU End of East

Pier

Twice Monthly During Above

Sampling Event Grab

Dry Dock Submergence

(002) Oil and Grease mg/L

Waters Above Dry

Dock (Sump End)

Quarterly Grab

Pressure Wash/Process

Water Discharges

(003)

Total Recoverable Copper, Zinc, Lead

mg/L Exit of EP

Treatment Unit

Quarterly Grab

3.2 Sampling Procedures

1. Laboratory-supplied sample bottles will be used to collect the sample.

2. The sample bottle will be capped, labeled, and preserved according to laboratory instructions.

3. The following items will be recorded at the time of sampling:

a. Sampling location (when there is more than one).

b. Date of sampling.

c. Time of sampling.

d. How sample was collected (for example, “grab”).

e. Name of the sampler(s).

f. Number, types (parameters) of samples collected.

g. Unusual circumstances that may affect the sample results, if any.

h. Unusual visual observations as described in Section 3.6, if any.

4. Samples will be sent to a laboratory registered or accredited under the provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories.

3.3 Special Considerations for Flow measurement, Field measurement, and Continuous Monitoring Devices:

1. Select and use appropriate flow measurement, field measurement, and continuous monitoring devices and methods consistent with accepted scientific practices.

2. Install, calibrate, and maintain these devices to ensure the accuracy of the measurements is consistent with the accepted industry standard and the manufacturer’s recommendation for that type of device.

3. Calibrate continuous monitoring instruments weekly unless it can demonstrate a longer period is sufficient based on monitoring records.

4. Use field measurement devices as directed by the manufacturer and do not use reagents beyond their expiration dates.

5. Calibrate these devices at the frequency recommended by the manufacturer.

6. Calibrate flow-monitoring devices at a minimum frequency of at least one calibration per year.

7. Maintain calibration records for at least three years.

3.4 Special Considerations for Oil and Grease Sampling

A solvent pre-rinsed one-liter glass bottle with a Teflon insert in the lid will be used to collect the sample. The sample will be preserved by adding sulfuric or hydrochloric acid to a pH of less than 2.0 and stored no longer than 28 days at four degrees C, until analyzed. Confirm with the analytical laboratory that the oil and grease sampling bottles provided already have the preservative added.

3.5 Sample Analysis, Handling and Preservation

Samples will be analyzed, handled, and preserved in accordance with Code of Federal Regulations (CFR) Title 40, Part 136. Samples will be submitted to a laboratory accredited by WAC 173-50, Accreditation of Environmental Laboratories.

3.6 Visual Observations

Visual Observations will include: presence of floating materials, visible sheen, discoloration, turbidity, odor, and other physical attributes of the stormwater discharges. Observations of the performance of the Best Management Practices (BMPs) described in this document will also be made, and if necessary, failing practices will be corrected.

Any oil sheens observed during sampling will be reported on the next scheduled DMR. The DMR will include the exact dates and times, the probable cause, and the steps taken or planned to reduce, eliminate, and prevent further contamination.

4. Best Management Practices

The following mandatory BMPs are implemented at this site. These BMPs are provided to all employees, contractors, and vessel owners.

Best Management Practices (BMPs) are required by our National Pollutant Discharge Elimination System (NPDES) permit. This permit is issued by the Washington State Department of Ecology. BMPs are activities that are designed to prevent or reduce the discharge of pollutants by companies or individuals. BMPs include maintenance, housekeeping, and materials management practices that minimize wastes from our shipyard activities and their use helps DCI comply with State and Federal laws which govern or prohibit the discharge of pollutants. Violation of these laws can result in fines and other penalties and consequences. It is also unethical to “dump” potential pollution problems on others. BMPs are to be observed by all shipyard employees as well as shipyard subcontractors and customers. Source reduction is our most effective pollution prevention opportunity, followed by recycling, treatment, and proper disposal. Pollution prevention and the prevention of accidental discharges of pollutants is DCI’s challenge to every person who enters the shipyard. Pollution prevention is accomplished by individuals doing due diligence when planning either individual jobs or future projects. Planning is the key element in pollution prevention and preventing accidental discharges of pollutants. Plan:

WHEN to do things WHERE to do things HOW to do things WHAT you do or don’t do

Understanding, planning, and involving all affected parties is important to the success of pollution prevention. In order to preserve the health of our community and the environment, the following facility-specific BMPs are to be observed by shipyard employees as well as all customers and subcontractors. Use these BMPs to guide worker activities with regard to pollution prevention as well as increase their awareness of their responsibilities for environmental compliance.

The list of BMPs is not exhaustive and is not intended to cover all situations that may arise in our shipyard. Always seek assistance from your supervisor, project manager, or DCI’s Environmental Compliance Manager if you have any questions or concerns with regard to pollution prevention and environmental compliance.

DCI BEST MANAGEMENT PRACTICES

1. Shipyard Customer Stormwater and Marine Pollution Prevention 2. Control of Large Solid Materials and Solid Waste

2a. Control of Metals

3. Yard Cleanup 4. Abrasive Blasting 5. Spray Painting 6. High Pressure Washing 7. In-Water Vessel Maintenance 8. Spill Prevention and Containment 9. Equipment Fueling and Liquid Transfer Operations 10. Informing Employees, Contractors, and Customers

Exhibit A

1. Shipyard Customer Stormwater and Marine Pollution Prevention Notification

It is a condition of our NPDES Permit that customers and contractors be notified in writing that they are bound by the same rules and regulations as DCI when at the shipyard. Our customers and contractors are to be informed with these BMPs and the attached notification (Exhibit A) or our Environmental Briefing Packet and Contractor Method Statement document which includes these BMPs and notification. Trained and responsible personnel for this BMP are from the following crews:

- Management

2. Control of Large Solid Materials and Solid Waste

Floatable and low density waste, such as wood, plastic, and miscellaneous trash, such as paper, insulation, and packaging, shall be removed from the drydock floors prior to flooding. All waste and trash shall be removed from the drydock and Syncrolift prior to flooding. The same is necessary for the entire shipyard in order to prevent solids from either entering the Guemes Channel, our stormwater system, or the sanitary sewer system. Material and pollutants can foul our stormwater and pressure wash water treatment facilities. The wind blows waste and trash which can end up in the wrong places. The rain washes waste and trash into the stormwater system if it is not picked up and cleaned up. Trash and waste need to be placed in appropriate lidded containers, or kept indoors. Vehicles can also spread and track waste and trash. Waste and trash can become safety hazards for all of us to be concerned about. It can’t be emphasized enough how important it is for each of us to take it upon ourselves to be constantly diligent about our cleanup habits. Solid Waste Handling

The Permittee shall handle and dispose of all solid waste material in such a manner as to prevent its entry into state ground or surface water.

Waste materials, including recyclables, need to be containerized and covered by law. Waste containers shall not leak and, unless authorized by the transfer station, all solid waste brought to the transfer station must “pass the paint filter test.” Liquids do not go into dumpsters or other waste containers destined for the transfer station.

2a. Control of Metals

While there are many metals deemed as potentially toxic pollutants under Washington State law, the primary metals associated with our activities are zinc, copper, lead, nickel, mercury, and aluminum. Most of our sources of metals contamination stem from our shipyard activities involving abrasive grit blasting, metal cutting and welding, vehicle traffic, painting operations, and outdoor storage. While some of these sources can be difficult to control as they are inherent to our work as a shipyard, some of the more easily controlled sources involve materials storage and handling activities and the segregation of stormwater from unnecessary industrial contamination.

In addition to the BMPs referenced throughout this document, specific attention needs to be given to control metals contamination from outdoor storage and handling of metals-containing materials and wastes.

Zinc anodes, whether new or used, need to be containerized and covered (protected from the elements) at all times.

Copper pipe, galvanized pipe, and other metal materials, whether new or used, need to be stored off the ground and under cover whenever possible.

Waste materials, including recyclables, need to be containerized and covered by law. With regard to segregation of stormwater from unnecessary industrial contamination, our hydroblast and pressure wash water is diverted to a treatment system designed for metals contamination reduction. Our stormwater is not as effectively treated; therefore, pollution prevention is our best choice for meeting our stormwater requirements.

Keeping blasting grit and debris materials out of our stormwater drains and system eliminates the need for expensive treatment of the large quantities of stormwater collected from our site.

Good housekeeping and the use of effective shrouds eliminates most of the potential for blasting grit to enter the stormwater system.

The blasting shed needs to be used and maintained to prohibit blasting grit and debris material from escaping the shed and entering the nearby stormwater drains and system.

Effective shrouds shall be used on projects that are too large for the blasting shed such that the blasting grit and debris material is contained and not entrained into stormwater or tracked away from the containment area by vehicle traffic such as fork trucks, man lifts, and Gators.

Prevent stormwater “run-on” and “run-off” – berm and cover work activities to the maximum extent feasible and divert stormwater away from process materials and waste.

Clean all equipment of blasting grit and other contamination prior to removal from area of use and containment.

Trained and responsible personnel for this BMP are from the following crews:

- Management

- Mechanics

- Tool Repair

- Stockroom

- Paint

- Fitters

- Welders

- Big House

- Repair

- Pipe

- Hydraulics/Sea Trails

- Electrical

- Outfitters

- Operators

- Machine Shop

3. Yard Cleanup

The entire shipyard as well as the area around each vessel as well as the vessels themselves should be cleaned on a daily basis. This includes the drydock and the Syncrolift. Vessel build, vessel repair, and vessel maintenance work generates many sources of pollutants. A clean shipyard provides an atmosphere that reduces the potential for pollution. Housekeeping in general is everyone’s responsibility. A job is not complete if the final cleanup, no matter its magnitude, is not complete. Trained and responsible personnel for this BMP are from the following crews:

- Management

- Mechanics

- Tool Repair

- Stockroom

- Paint

- Fitters

- Welders

- Big House

- Repair

- Pipe

- Hydraulics/Sea Trails

- Electrical

- Outfitters

- Operators

- Machine Shop

4. Abrasive Blasting

Dust and abrasive blasting grit shall be prevented from entering nearby waters and storm drains. Removal of marine growth prior to blasting reduces the potential for airborne fugitive emissions during abrasive blasting. Pressure washing of vessels prior to grit blasting to minimize the potential for fugitive emissions is recommended whenever possible. Conduct abrasive blasting on the drydock whenever possible. The drydock, when properly shrouded, is the best control of dust and sand grit available for this type of work. The wing walls are 30+ feet high with tarps to enclose the ends. Added screening is to be considered whenever necessary for added protection in preventing pollution situations. Modifications such as installation of tie rings or cleats, cable suspension systems or scaffolding can make the implementation of this BMP easier. The bottom edge of tarpaulins and plastic sheeting shall be weighted or fastened to remain in place during windy conditions. Project Managers or Supervisors are responsible for constant monitoring of blasting in order to control fallout of pollutants. When conditions dictate, curtail blasting until favorable conditions are present. Avoid blasting that could impact the community or environment in any negative way. Project Managers or Supervisors are responsible for ensuring:

a) Dust and abrasive grit shall be confined to the shipyard to the maximum extent feasible during blasting operations. b) The drydock shall be cleaned of sandblast grit, waste and trash prior to launching a vessel. c) Photographs shall be taken and maintained in a logbook to demonstrate the condition of the drydock floor prior to launching every vessel. Documentation accompanying the photographs shall include the name of the vessel, the drydock number, the date the vessel was launched, the date the photograph was taken, and the name of the photographer.

Noise abatement from abrasive blasting is best achieved by limiting the number of nozzles used whenever possible. Projects need to be scheduled and monitored for this requirement. Over exuberance of the use of too many nozzles can produce noise and nuisance dust that is not tolerable by the local community.

The use of temporary barriers not only helps to control the fallout of dust, but also can soften the noise from the operation. The use of temporary barriers is required by the Northwest Clean Air Agency to control and minimize air emissions. Cleanup of blast abrasive and other debris must be conducted daily. Power and manual sweeping is important for reducing the potential for fallout to become airborne or subsequently waterborne. Abrasive grit when spilled on the ground in the yard should be immediately cleaned up. Vessel hull abrasive blasting is prohibited while the vessels are in the water. A containment berm must be in place when using portable compressors. The containment should be clean and in good condition. It should be relocated every time the compressor is moved. Trained and responsible personnel for this BMP are from the following crews:

- Management

- Paint

5. Spray Painting

Overspray shall be prevented from falling into the water during spray painting. Feasible methods such as tarps and screens must be used to accomplish this BMP. Conduct spray painting on the drydock whenever possible. The drydock, when properly shrouded, is the best control of overspray available for this type of work. The wing walls are 30+ feet high with tarps to enclose the ends. Added screening is to be considered whenever necessary for added protection in preventing overspray situations. Feasible modifications can make the implementation of this BMP easier. The bottom edge of tarpaulins and plastic sheeting shall be weighted or fastened to remain in place during windy conditions. Project Managers and Supervisors are responsible for monitoring spray painting operations in order to control overspray situations. When conditions dictate, curtail spray painting until favorable conditions are present. Avoid spray painting overspray that could impact the community or the environment in any negative way. Overspray shall be confined to the worksite to the maximum extent feasible during spray painting operations. The use of temporary barriers helps to control overspray and is required by the Northwest Clean Air Agency to control and minimize air emissions. Vessel hull spray painting is prohibited while the vessels are in the water. A containment berm must be in place when using portable compressors. The containment should be clean and in good condition. It should be relocated every time the compressor is moved. Trained and responsible personnel for this BMP are from the following crews:

- Management

- Paint

6. High Pressure Washing

Vessel hull pressure washing is prohibited while vessels are in the water. Conduct pressure washing on the drydock or the Syncrolift transfer area only. These are the best containment areas for pressure washing water recovery for treatment of the water. No pressure washing is allowed on that portion of the Syncrolift which is over the water unless special provisions have been made to assure that wastewater is not released into the channel waters. Project Managers and Supervisors will monitor all pressure washing to assure that pressure wash wastewater is contained, collected, and subsequently treated. Use whatever barriers necessary to control fallout and discharge of pollutants. Pressure washing operations on the drydock will commence only after the sump and the “orange vacuum trailer” have been properly commissioned for the particular job. Both the sump and the “orange vacuum trailer” must be monitored to prevent overflow of either the sump or the trailer. This monitoring responsibility is crucial. Leaking connections, valves, pipes, hoses, and soil chutes carrying either water or wastewater shall be replaced or repaired immediately. Soil chute and hose connections to vessels and to receiving lines or containers shall be tightly connected and as leak free as practicable. Trained and responsible personnel for this BMP are from the following crews:

- Management

- Mechanics

- Paint

7. In-Water Vessel Maintenance

The cleaning of any portion of a vessel’s hull below the waterline while the vessel is in the water is prohibited. DCI would prefer not to work on vessel hulls when they are still in the water. There are specific conditions found in our NPDES Permit that address working on vessel hulls above the water line when they are still in the water. These activities are only allowed provided that containment and collection BMP measures are in effect to prevent the introduction of dust, dirt, debris, or any other pollutants generated from these surface preparation operations from being deposited on or entering into waters of the state:

Mechanical hand preparation, such as scraping or wire brushing

Conventional mechanical grinding or use of other powered mechanical abrading tools

Conventional abrasive blasting on the vessel's hull while it is in the water is prohibited. The following methods of paint and coating applications to a vessel's hull while in the water at an NPDES permitted shipyard are allowed provided that all containment, collection, and spill prevention BMPs are in place before any such applications are made to a vessel's hull.

Application by roller

Application by brush

Conventional spray-paint or spray-coating applications to a vessel's hull while that vessel is in the water are prohibited.

Floats are defined as free-floating, unattached work platforms capable of moving back and forth along the length of the ship and around its hull. Floats shall at all times maintain a minimum of 1" of freeboard at the floats lowest point during all phases of maintenance operations. The minimum 1" freeboard requirement must be maintained with all scaffolding configurations and number of persons on board the float. All necessary precautions will be taken by personnel on board the float to prevent paints, cleaning materials, petroleum products, all other liquids and unsecured materials from entering into the water from the float.

Any container of paint, marine coating or any other liquid product for painting or surface preparation of one gallon or greater must be provided with secondary containment when used on board a float. All roller pans used on a float must be provided with secondary spill containment. Secondary spill containment capacity is equal to the entire volume of the container plus 10% of the volume of that same container. Documentation requirements will be in effect for any in-water surface preparation operations of one hour or more in duration and any in-water coating or painting operation involving 1/2 gallon or more of paint or marine coating. Documentation requirements will consist, at a minimum, of one or more representative photographs of all in-water vessel maintenance BMPs which are implemented for surface preparation operations and all painting and coating operations. All such photographs shall be dated and maintained in a logbook with all necessary descriptive narrative of the in-water vessel maintenance BMPs being documented. These records shall be made available to a Department of Ecology inspector upon request and will be retained on site for at least three years. Trained and responsible personnel for this BMP are from the following crews:

- Management

- Paint

8. Spill Prevention and Containment

A. No discharge of oil, paint or other hazardous material shall be allowed into state waters.

No discharge of oil, other hazardous material, or paint to state waters is allowed, except as specifically authorized by this permit. Oil, grease, fuel, or paint spills shall be prevented from reaching drainage systems or surface waters. Cleanup shall be carried out promptly after an oil, grease, fuel, or paint spill is detected. Oil containment booms and absorbents shall be conveniently stored so as to be immediately deployable in the event of a spill. All yard personnel that may participate in cleanup of spills shall be trained in the use and deployment of cleanup equipment.

In the event of an accidental discharge of oil or hazardous material into waters of the state or onto land with a potential for entry into state waters, the Department's Northwest Regional Office Spill Response Section and the United States Coast Guard shall be notified immediately. Notify the ECM immediately of any spill and provide incident documentation within 12 hours. Emergency contact information shall be legibly posted at the Dangerous Waste Area and all Satellite Accumulation Areas.

1. Cleanup efforts shall commence immediately and be completed as soon as possible, taking precedence over normal work, and shall include proper disposal of spilled material and used cleanup material.

2. Cleanup of oil or hazardous material spills shall be in accordance with an approved spill control plan or according to specific instructions of an on-scene coordinator.

3. No emulsifiers or dispersants are to be used in or upon the waters of the state without prior approval from the Director of the Department of Ecology. Drip pans or other protective devices shall be required for all oil transfer operations to catch incidental spills and drips from hose nozzles, hose racks, drums, or barrels. Oils and fuel storage tanks shall be provided with secondary containment.

B. The mixing of paints and solvents shall be carried out in locations and under conditions such that no spill shall enter the environment or state waters.

1. Drip pans or other protective devices shall be required for all paint mixing and solvent transfer operations, unless the mixing operation is carried out in covered and controlled areas away from storm drains, surface waters, shorelines, and piers. Drip pans, drop cloths, or tarpaulins shall be used

wherever paints and solvents are mixed on wood docks. Paints and solvents shall not be mixed on floats.

2. Paint and solvent spills shall be treated as oil spills and shall be prevented from

reaching storm drains and subsequent discharge into the water.

Mixing activities will be conducted within the confines of the portable paint booth containments or on the palletized portable containments.

C. Using the least amounts of thinner practical will help to minimize the release of Volatile Organic Compounds (VOC’s). All used thinner is to be properly handled and stored. All waste thinner is shipped under manifest to a certified TSDR facility (treat, store, dispose of or recycle hazardous waste facility).

D. Solid chemicals, chemical solutions, paints, oils, solvents, acids, caustic solutions, and

waste materials, including used batteries, shall be stored in a manner which will prevent the inadvertent entry of these materials into waters of the state, including ground water. Storage shall be in a manner that will prevent spills due to overfilling, tipping, or rupture. In addition, the following practices shall be used:

1. All liquid products shall be stored on durable impervious surfaces and within bermed containment capable of containing 110% of the largest single container in the storage area. 2. Waste liquids shall be stored under cover, such as tarpaulins or roofed structures. All waste storage areas, whether for waste oil or hazardous waste, shall be clearly designated as such and kept segregated from new product storage. 3. Incompatible or reactive materials shall be segregated and securely stored in separate containment areas that would prevent the inadvertent mixing and reaction of spilled chemicals. 4. Concentrated waste or spilled chemicals shall be transported off-site for disposal at a facility approved by the Department of Ecology or appropriate county health authority… These materials shall not be discharged to any sewer or state waters.

E. Any intercepted chemical spill shall be recycled back to the appropriate chemical solution tank or cleaned up and disposed of properly. The spilled material must be handled, recycled, or disposed of in such a manner as to prevent its discharge into state waters.

F. A containment berm must be in place when using portable compressors or other equipment with the potential for leaks or spills. The containment should be clean and in good condition. It should be relocated every time the equipment is moved.

G. Leaking connections, valves, pipes, hoses, and soil chutes carrying either water or

wastewater shall be replaced or repaired immediately. Soil chute and hose connections to vessels and to receiving lines or containers shall be tightly connected and as leak free as practicable.

H. Scuppers on the dry dock are to be blocked whenever work is being conducted on the dry

dock deck or on a vessel occupying the dry dock. Scuppers and overboard discharge ports are to be blocked while any vessel is on the dry dock or is tied alongside any DCI pier.

I. All containers are to be clearly labeled, securely closed when not in active use, and on

appropriate secondary containment. J. Access to the Dangerous Waste Area (DW-1) is restricted to trained, authorized employees

only, unless accompanied by a trained, authorized employee. K. Hazardous wastes are to be handled by trained, authorized employees only. Call

Environmental if unsure of your waste type or for assistance with handling, storage, and disposal of wastes.

Trained and responsible personnel for this BMP are from the following crews:

- Management

- Mechanics

- Tool Repair

- Stockroom

- Paint

- Fitters

- Welders

- Big House

- Repair

- Pipe

- Hydraulics/Sea Trails

- Electrical

- Outfitters

- Operators

- Machine Shop

9. Equipment Fueling and Liquid Transfer Operations

1. Store fuels and liquids in proper, sealed, and clearly labeled containers within secondary containment. Containers must be labeled with contents and risks and kept closed and sealed at all times, except when adding or removing fluids. Regulators categorize diesel fuel as a Class II Combustible Liquid, whereas they categorize gasoline as a Flammable Liquid.

2. Provide secondary containment around fuel and liquid storage containers and at

transfer points. Maintain a watch at each transfer point/end of hose during transfer operations.

3. Operate and maintain equipment so as to prevent spills, leaks, and drips. Have spill prevention and cleanup materials readily available at fuel and liquid transfer locations.

Secondary containment equipment used during mobile fueling and liquid transfer operations shall be sized to contain the most likely volume of liquid to be spilled during a transfer. Portable containment equipment shall be positioned to catch any spills due to overfilling the equipment and any other spills that may occur at or near the filler port of the equipment. The selection of containment equipment and its positioning and use shall take into account all the drip points associated with the filling port and the hose from the delivery truck/tank. See Figures 1A, 1B, and 2 for examples of portable spill containment that may be used during fueling and liquid transfer operations. Trained personnel must remain in attendance of the transfer process to ensure that any spills will be of limited volume. Trained personnel must ensure the presence and constant observation/monitoring of the driver/operator at the transfer location at all times during the transfer and ensure implementation of the following procedures at the transfer locations:

o Locate the point of fueling at least 25 feet from the nearest storm drain, or inside an impervious containment with a volumetric holding capacity equal to or greater than 110 percent of the fueling tank volume, or cover the storm drain with an approved portable mat (see Figure 3) to ensure no inflow of spilled or leaked liquids can occur.

o Place a drip pan with an absorbent pad under each fuel and liquid transfer location prior to and during all dispensing operations. The pan must be liquid

tight have a capacity of at least 5 gallons. There is no need to report spills retained in the drip pan or on the pad.

o Manage the handling and operation of transfer hoses and nozzles, drip pan(s),

and absorbent pads as needed to prevent spills/leaks/drips from reaching the ground, storm drain, or receiving waters.

o Use an absorbent pad to carry the tip of the nozzle to and from the receiving equipment/tank/container and to wipe the nozzle clean and dry after the transfer.

o Remove the fill nozzle and cease filling the tank when the automatic shut-off

valve engages. Do not lock automatic shutoff fueling nozzles in the open position. Do not “top off” the receiving equipment.

Operators must be trained annually in spill prevention and cleanup measures and emergency procedures. All employees are to be made aware of the significant liability associated with fuel spills and unpermitted liquid discharges to storm drains and waterways.

Maintain and make readily available for use a minimum of the following spill clean-up materials:

o Non-water absorbents capable of absorbing at least 15 gallons of diesel fuel. o A storm drain plug or cover kit. o A non-water absorbent containment boom of a minimum 10 feet in length with a

12-gallon minimum absorbent capacity. o A non-spark generating shovel (a steel shovel could generate a spark and cause

an explosion in the right environment around a spill).

Maintain and replace equipment on fueling vehicles, particularly hoses and nozzles, at established intervals to prevent failures. Refueling containers (skid-mounted tanks, drums, five gallon cans) must have secondary containment. Secondary containment areas for fuel storage tanks must be able to contain 110 percent of the volume of the largest fuel storage container and have an impervious floor. DCI personnel, customers, and contractors of oil transfer operations, including on site fueling of trucks, storage tanks, and vessels, must follow DCI’s Oil Transfer Operations policy.

Filling Portable Gasoline Containers

Before filling, always remove the container from the vehicle and place it on the ground at a safe distance from the vehicle (provides path to dissipate static charge to ground).

Touch the container with the fuel dispenser nozzle before removing the container cap (provides another path to dissipate static charge to ground).

Bring the nozzle in contact with the inside of the fill opening before operating the nozzle. Maintain contact until the filling operation is complete (to dissipate static charge buildup from flow of gasoline).

Never use the latch-open device, equipped on some dispensing nozzles, to fill a portable container.

Fill container no more than 95 percent full to allow for expansion.

Place cap tightly on the container after filling - do not use containers that do not seal properly.

Oil Transfer Operations See Oil Transfer Operations at DCI and Focus on Oil Transfer Requirements for policies regarding large volume fuel and oil transfer operations. Ensure related documentation is provided to Environmental each time an oil transfer occurs.

Figure 2

Figure 3 Storm Drain Mat

Trained and responsible personnel for this BMP are from the following crews:

- Management

- Mechanics

- Repair

- Hydraulics/Sea Trials

- Operators

10. Informing Employees, Contractors, and Customers DCI’s methods of informing employees, contractors, and customers of our BMPs include:

a) New-hire orientations b) Monthly newsletters c) Safety, supervisor, management, and other company meetings d) Annual refresher training specific to each DCI crew e) Customers and contractors being informed through Project Managers, Supervisors, and those who are most directly interfacing with our customers and sub-contractors

Trained and responsible personnel for this BMP are from the following crews:

- Management

Exhibit A

Customer Environmental Compliance There are numerous probable pollution discharges by marine vessels whether moored or dry-docked at a shipyard. It is the responsibility of the vessel’s Master and Crew to comply with all Federal, State, and Local laws on environmental protection issues when at a shipyard. Shipyard customers are subject to the same rules with regard to environmental pollution as the shipyard itself. Violations of the Clean Air Act and the Clean Water Act may result in fines and possible criminal prosecution. All DCI BMPs must be followed. Discharges of pollutants to the land, water, or air are prohibited at DCI’s shipyard.

In the event of a spill, pollutants shall be contained and cleaned up immediately and shipyard management informed without delay.

ADDITIONAL REQUIRED BEST MANAGEMENT PRACTICES

11. Upland Vessel Maintenance and Repair

When stripping, sanding, scraping, sandblasting, painting, coating, or varnishing any portion of a vessel, all particles, oils, grits, dusts, flakes, chips, drips, sediments, debris and other solids shall be collected and managed to prevent their release into the environment and entry into waters of the state.

Drop cloths, tarpaulins, structures, drapes, shrouding, or other protective devices shall be secured around the vessel, as necessary, to collect all such materials. The cleanup of all collected materials shall be routinely undertaken to prevent their release into the environment and entry into waters of the state.

12. Oils and Bilge Water Management

Hydraulic fluids, oily wastes, and petroleum products shall not be discharged to waters of the state. Bilge water discharges shall not cause any visible sheen in waters of the state.

Bilge waters shall not be discharged to waters of the state if solvents, detergents, emulsifying agents, or dispersants have been added to the bilge. If a vessel is moved prior to pumping out the bilge, absorbent pads shall be used to prevent the accidental discharge of oils to waters of the state.

Drip pans or other containment devices shall be used during all petroleum product transfer operations to catch incidental leaks and spills. Absorbent pads and booms shall be available during petroleum transfer operations occurring over water.

13. Sacrificial Anode (Zincs) Management

Zincs used as sacrificial anodes shall not be disposed of into waters of the state. Spent zincs shall be stored in a covered container and be recycled for their material value.

14. Chemical Management

Solid chemical products, chemical solutions, paints, oils, solvents, acids, caustic solutions and waste materials, including used batteries, lead, and copper waste, shall be stored under cover on an impervious surface.

All chemical liquids and fluids shall be stored on a durable impervious bermed surface capable of containing 10 percent of the total tank and container volume or 110 percent of the largest tank or container volume, whichever is greater.

15. Wash Pad Decontamination

Prior to actively pumping or passively discharging any stormwater from the pressure wash pad to waters of the state, the pad shall be cleaned of all debris, paint waste, sludge, and other solids. Then the entire pad shall be pressure washed into the collection sump and the sump cleaned of all debris and other solids.

16. Sewage and Gray Water Discharges

Owners of vessels moored for repair or under repair at a permitted facility shall be notified in writing by the Permittee that this permit prohibits the discharge of sewage (including discharges from the vessel's galley) into waters of the state. Sanitary waste discharges shall be to either the sanitary sewer or into a holding tank. The Permittee shall make available to customers a list of contractors providing holding tank pump-out services.

17. Good Housekeeping

Implement the following good housekeeping activities at the site:

Clean regularly all accessible work, service and storage areas to remove debris, spent sandblasting material, and any other potential stormwater pollutants.

Promptly contain and clean up solid and liquid pollutant leaks and spills including oils, solvents, fuels, and dust from manufacturing operations on any soil, vegetation, or paved area exposed to stormwater.

Sweep paved material handling and storage areas regularly as needed to collect and dispose of dust and debris that could contaminate stormwater. Do not hose down pollutants from any area to the ground, storm drain, conveyance ditch, or receiving water unless necessary for dust control purposes to meet air quality regulations and

unless the pollutants are conveyed to a treatment system approved by the local jurisdiction.

Collect spent abrasives regularly and store under cover to await proper disposal.

Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers properly.

Convey sanitary sewage to pump-out stations, portable on-site pump-outs, or commercial mobile pump-out facilities or other appropriate onshore facilities.

Maintain automatic bilge pumps in a manner that will prevent waste material from being pumped automatically into surface water.

Prohibit uncontained spray painting, blasting or sanding activities over open water.

Do not dump or pour waste materials down floor drains, sinks, or outdoor storm drain inlets that discharge to surface water. Plug floor drains that are connected to storm drains or to surface water. If necessary, install a sump that is pumped regularly.

Prohibit outside spray-painting, blasting, or sanding activities during windy conditions that make containment ineffective.

Immediately clean up any spillage on dock, boat, or ship deck areas and dispose of the wastes properly.

Perform paint related activities such as paint mixing, solvent mixing, and fuel mixing onshore in an area where spills are contained.

Clean oils, debris, sludge, or other objects from all BMP systems regularly, including catch basins, sedimentation basins, oil/water separators, boomed areas, and conveyance systems, to prevent the contamination of stormwater.

Promptly repair or replace all substantially cracked or otherwise damaged paved secondary containment, high-intensity parking, and any other drainage areas, which are subjected to pollutant material leaks or spills.

Promptly repair or replace all leaking connections, pipes, hoses, valves, or other equipment objects that can contaminate stormwater.

Use solid absorbents, for example, clay, peat absorbents, and rags for cleanup of liquid spills/leaks, where practicable.

18. Preventive Maintenance

Implement the following preventive maintenance activities at the site:

Prevent the discharge of unpermitted liquid or solid wastes, process wastewater, and sewage to ground or surface water or to storm drains, which discharge, to surface water or to the ground. Floor drains in potential pollutant source areas shall not be connected to storm drains, surface water, or to the ground. Eliminate illicit non-stormwater discharges as soon as possible but no later than 30 days of discovery.

Conduct all oily parts cleaning in a self-contained system. When steam cleaning or pressure washing equipment and containers, either inside a building or outside on an impervious contained area (such as a concrete bermed pad), ensure all wash water is completely recycled or sent to a municipal sewage treatment system. Prevent all contaminated wash water and stormwater originating from these areas from entering either surface waters or storm drains that discharge to surface waters.

Do not pave over contaminated soil unless it has been determined that groundwater has not been and will not be contaminated by the soil.

Construct impervious areas that are compatible with the materials handled. Consider using Portland cement concrete, asphalt, or equivalent material.

Use drip pans to collect leaks and spills from equipment such as cranes, industrial parts, trucks, and other vehicles that are stored outside. After a spill or leak is collected in an uncovered area, empty drip pan immediately.

Drain oil from fuel filters before disposal. Discard empty oil filters, fuel filters, oily rags, and other oily solid waste into appropriately closed and properly labeled containers and in compliance with the Uniform Fire Code.

For the storage of liquids use containers, such as steel and plastic drums, that are rigid and durable, corrosion resistant to the weather and fluid content, non-absorbent, water tight, rodent-proof, and equipped with a close fitting cover.

For the temporary storage of solid wastes contaminated with liquids or other potential pollutant materials use dumpsters, garbage cans, drums and comparable containers that are durable, corrosion resistant, non-absorbent, non-leaking, and equipped with either a solid cover or screen cover to prevent littering. If covered with a screen, the container must be stored under a lean-to or equivalent structure.

Store cracked batteries in a covered secondary container.

Where exposed to stormwater, use containers, piping, tubing, pumps, fittings, and valves that are appropriate for their intended use and for the contained liquid.

Inspect and maintain stormwater drainage and treatment systems and equipment and systems that could fail and result in contamination of stormwater. To obtain and ensure proper operation and performance, regularly maintain and clean out debris, sediments, and oil from stormwater collection, conveyance, and treatment systems.

Provide maintenance and cleaning of debris, sediments and oil from stormwater collection, conveyance and treatment systems to obtain proper operation and performance.

Use plastic or tarpaulin barriers beneath the hull to contain and collect waste and spent materials when the dry dock or rails are not able to contain the waste and debris. Clean and sweep regularly to remove debris.

Enclose, cover, or contain blasting and sanding activities to the maximum extent practicable to prevent abrasives, dust, and paint chips, from reaching storm sewers or receiving water. Use plywood or plastic sheeting to cover open areas between decks when sandblasting (scuppers, railings, freeing ports, ladders, and doorways).

Ensure stormwater from areas with little or no exposure to pollutants (for example, infrequently used parking areas or roof drainage) is diverted away from areas of high pollutant exposure (for example, a hull refinish area.) Examples include, but are not limited to: drains, ditches, temporary or permanent berms, or walls.

19. Employee Training

Training must include an overview of what is in the SWPPP and how employees make a difference in complying with the SWPPP and preventing contamination of stormwater. All employees who work in pollutant source areas are trained in identifying pollutant sources and in understanding pollutant control measures, spill prevention and response, good housekeeping, and environmentally acceptable material handling and management practices. Training is scheduled and implemented by Human Resources as described in DCI’s Dangerous Waste and Environmental Training Plan. Training topics and crew responsibilities are summarized in Table 1. Training is conducted annually, at a minimum.

Table 1. BMP Training by Crew

Shipyard Customer

Stormwater and Marine

Pollution Prevention Notification

Control of Larger Solid Materials

and Solid Waste Yard Cleanup Abrasive Blasting Spray Painting High Pressure

Washing

In-Water Vessel

Maintenance

Spill Prevention and

Containment

Equipment Fueling

and Liquid Transfer

Operations

Informing Employees,

Contractors, and Customers

Crew 1 - Main Office

Management X X X X X X X X X X

Admin 5 - Support

Mechanics X X X X X Tool Repair X X Stockroom X X

Security 10 & 11 - Paint X X X X X X X 15 - Engineering Office

Safety 25 - Fitters X X 30 - Welders X X 35 - Big House X X 40 - Repair X X X X 50 - Pipe X X 51 - Hydraulics/Sea Trials X X X X 60 - Electrical X X 70 - Outfitters X X 80 - Operators X X X X 90 - Machine Shop X X X X Training Methods

Orientation X X X X X X X X X X

Supervisor Meetings X X X X X X X X X X

Management Meetings X X

Annual Refreshers X X X X X X X

20. Inspections and Recordkeeping

Each crew supervisor is responsible for inspecting BMPs for use and effectiveness prior to operations with the Yard Supervisor and Project Managers providing backup assurance. Dry dock logs showing dates and times of submergences and compliance with BMPs are kept by the dry dock operator(s). Dry dock deck photos are taken by the cleaning crew before submerging and provided to the Environmental Compliance Manager. Environmental staff inspects yard storm drains and recommends cleaning and maintenance to management. Inspection and maintenance targets are as below:

Task Min. Frequency

Clean out storm drain catch bags Quarterly

Inspect/remove floatables from all storm drains Monthly

Storm drain spill covers checked Monthly

Replace AQUIP oil skimmer donut Quarterly

Replace beige tank oil skimmer booms Quarterly

Storm drain plugs checked Quarterly

Replace storm drain catch bags Annually

Vacuum clean Mechanics wash pad system Semiannually

Jet and vacuum clean storm drain system Every five years

AQUIP Media/Topper As needed

Other Related Tasks

Sweep pavement (logged on timecards) Weekly

Litter Patrol (logged on timecards) Weekly

Spill kits checked Monthly

Notes

Inspection abnormalities/other maintenance As needed

Operation and maintenance log sheets are maintained for the electrocoagulation, stormwater treatment, and waste water treatment units by Environmental staff.

21. S401 BMPs for the Building, Repair, and Maintenance of Boats and Ships

DCI’s BMPs emphasize most of the required S401 BMPs. The full text of the required S401 BMPs that need to be adhered to at all times is as follows: Description of Pollutant Sources: Sources of pollutants for the building, repair, and maintenance of boats and ships at boatyards, shipyards, ports, and marinas include pressure washing, surface preparation, paint removal, sanding, painting, engine maintenance and repairs, and material handling and storage, if conducted outdoors. Potential pollutants include spent abrasive grits, solvents, oils, ethylene glycol, washwater, paint over-spray, cleaners/detergents, anti-corrosive compounds, paint chips, scrap metal, welding rods, resins, glass fibers, dust, and miscellaneous trash. Pollutant constituents include TSS, oil and grease, organics, copper, lead, tin, and zinc. Pollutant Control Approach: Apply good housekeeping, preventive maintenance, and cover and contain BMPs in and around work areas.

Applicable Operational BMPs: Ecology’s NPDES Boatyard General Permit requires coverage of all boatyards in Washington State which engage in the construction, repair and maintenance of small vessels, 85% of which are 65 feet or less in length, or revenues from which constitute more than 85% of gross receipts. Ecology may require coverage under an individual NPDES permit for large boatyards and shipyards in Washington State not covered by the Boatyard General Permit or Industrial Stormwater General Permit (ISGP). The applicable operational BMPs are: Clean regularly all accessible work, service, and storage areas to remove debris, spent

sandblasting material, and any other potential stormwater pollutants.

Avoid the use of soaps, detergents and other chemicals that need to be rinsed or hosed off in the water. If necessary, consider applying sparingly so that a sponge, towel or rag can be used to remove residuals. Consider instead washing the boat in a suitable controlled area (see S431 BMPs for Washing and Steam Cleaning Vehicles/ Equipment/ Building Structures) while it is out of the water.

Sweep rather than hose debris on the dock. Collect and convey hose water to treatment if hosing is unavoidable,

Collect spent abrasives regularly and store under cover to await proper disposal.

Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers properly.

Drain oil filters before disposal or recycling.

Immediately repair or replace leaking connections, valves, pipes, hoses and equipment that causes the contamination of stormwater.

Use drip pans, drop cloths, tarpaulins, or other protective devices in all paint mixing and solvent operations unless carried out in impervious contained and covered areas.

Convey sanitary sewage to pump-out stations, portable on-site pumpouts, or commercial mobile pump-out facilities or other appropriate onshore facilities.

Maintain automatic bilge pumps in a manner that will prevent automatic pumping of waste material into surface water.

Prohibit uncontained spray painting, blasting or sanding activities over open water.

Do not dump or pour waste materials down floor drains, sinks, or outdoor storm drain inlets that discharge to surface water. Plug floor drains connected to storm drains or to surface water. If necessary, install a regularly operated sump pump.

Applicable Structural Source Control BMPs:

Use fixed platforms with appropriate plastic or tarpaulin barriers as work surfaces and for containment when performing work on a vessel in the water to prevent blast material or paint overspray from contacting stormwater or the receiving water. Keep use of such platforms to a minimum and do not perform extensive repair or construction in the water (anything in excess of 25 percent of the surface area of the vessel above the waterline).

Use plastic or tarpaulin barriers beneath the hull and between the hull and dry dock walls to contain and collect waste and spent materials. Clean and sweep regularly to remove debris.

Enclose, cover, or contain blasting and sanding activities to the maximum extent practicable to prevent abrasives, dust, and paint chips, from reaching storm sewers or receiving waters. Use plywood and/or plastic sheeting to cover open areas between decks when sandblasting (scuppers, railings, freeing ports, ladders, and doorways).

Direct deck drainage to a collection system sump for settling and/or additional treatment.

Store cracked batteries in covered secondary containers.

22. S431 BMPs for Washing and Steam Cleaning Vehicles/ Equipment/ Building Structures

DCI’s BMPs emphasize most of the required S426 BMPs. The full text of the required S426 BMPs that need to be adhered to at all times is as follows:

Description of Pollutant Sources: Pollutant sources include the commercial cleaning of vehicles, aircraft, vessels, and other transportation, restaurant kitchens, carpets, and industrial equipment, and large buildings with low- or high-pressure water or steam. This includes “charity” car washes at gas stations and commercial parking lots. The cleaning can include hand washing, scrubbing, sanding, etc. Washwater from cleaning activities can contain oil and grease, suspended solids, heavy metals, soluble organics, soaps, and detergents that can contaminate stormwater.

Pollutant Control Approach: The preferred approach is to cover and/or contain the cleaning activity, or conduct the activity inside a building, to separate the uncontaminated stormwater from the washwater sources. Convey washwater to a sanitary sewer after approval by the local sewer authority. Provide temporary storage before proper disposal, or recycling. Under this preferred approach, no discharge to the ground, to a storm drain, or to surface water should occur.

Applicable Structural Source Control BMPs: Conduct vehicle/ equipment washing in one of the following locations:

At a commercial washing facility in which the washing occurs in an enclosure and drains to the sanitary sewer, or

In a building constructed specifically for washing of vehicles and equipment, which drains to a sanitary sewer.

Conduct outside washing operation in a designated wash area with the following features:

In a paved area, construct a spill containment pad to prevent the run-on of stormwater from adjacent areas. Slope the spill containment area to collect washwater in a containment pad drain system with perimeter drains, trench drains or catchment drains. Size the containment pad to extend out a minimum of four feet on all sides of the washed vehicles and/or equipment.

Convey the washwater to a sump (like a grit separator) and then to a sanitary sewer (if allowed by the local Sewer Authority), or other appropriate wastewater treatment or recycle system. The containment sump must have a positive control outlet valve for spill control with live containment volume, and oil/water separation. Size the minimum live storage volume to contain the maximum expected daily washwater flow plus the

sludge storage volume below the outlet pipe. Shut the outlet valve during the washing cycle to collect the washwater in the sump. The valve should remain shut for at least two hours following the washing operation to allow the oil and solids to separate before discharge to a sanitary sewer.

Close the inlet valve in the discharge pipe when washing is not occurring, thereby preventing the entry of uncontaminated stormwater into the pretreatment/ treatment system. The stormwater can then drain into the conveyance/discharge system outside of the wash pad (essentially bypassing the sanitary sewer or recycle system). Post signs to inform people of the operation and purpose of the valve. Clean the concrete pad thoroughly until there is no foam or visible sheen in the washwater prior to closing the inlet valve and allowing uncontaminated stormwater to overflow and drain off the pad.

Collect the washwater from building structures and convey it to appropriate treatment such as a sanitary sewer system if it contains oils, soaps, or detergents. If the washwater does not contain oils, soaps, or detergents (in this case only a low pressure, clean, cold water rinse is allowed) then it could drain to soils that have sufficient natural attenuation capacity for dust and sediment.

23. S426 BMPs for Spills of Oil and Hazardous Substances

DCI’s BMPs emphasize most of the required S426 BMPs. The full text of the required S426 BMPs that need to be adhered to at all times is as follows:

Description of Pollutant Sources: Federal law requires owners or operators of facilities engaged in drilling, producing, gathering, storing, processing, transferring, distributing, refining, or consuming oil and/or oil products to have a Spill Prevention and Emergency Cleanup Plan (SPECP). The SPECP is required if the above ground storage capacity of the facility, is 1,320 gallons or more of oil. Additionally, the SPECP is required if any single container with a capacity in excess of 660 gallons and which, due to their location, could reasonably be expected to discharge oil in harmful quantities, as defined in 40 CFR Part 110, into or upon the navigable waters of the United States or adjoining shorelines {40 CFR 112.1 (b)}. Onshore and offshore facilities, which, due to their location, could not reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines are exempt from these regulations {40 CFR 112.1(1)(i)}. State Law requires owners of businesses that produce dangerous wastes to have a SPECP.

Pollutant Control Approach: Maintain, update, and implement a Spill Prevention and Emergency Cleanup Plan.

Applicable Operational BMPs: The businesses required to prepare and implement a Spill Prevention and Emergency Cleanup Plan shall implement the following:

Prepare a Spill Prevention and Emergency Cleanup Plan (SPECP), which includes:

A description of the facility including the owner's name and address.

The nature of the activity at the facility.

The general types of chemicals used or stored at the facility.

A site plan showing the location of storage areas for chemicals, the locations of storm drains, the areas draining to them, and the location and description of any devices to stop spills from leaving the site such as positive control valves.

Cleanup procedures.

Notification procedures used in the event of a spill, such as notifying key personnel. Agencies such as Ecology, local fire department, Washington State Patrol, and the local Sewer Authority, shall be notified.

The name of the designated person with overall spill cleanup and notification responsibility.

Train key personnel in the implementation of the SPECP. Prepare a summary of the plan and post it at appropriate points in the building, identifying the spill cleanup coordinators, location of cleanup kits, and phone numbers of regulatory agencies to contact in the event of a spill.

Update the SPECP regularly.

Immediately notify Ecology, the local jurisdiction, and the local Sewer Authority if a spill may reach sanitary or storm sewers, ground water, or surface water, in accordance with federal and Ecology spill reporting requirements.

Immediately clean up spills. Do not use emulsifiers for cleanup unless there is an appropriate disposal method for the resulting oily wastewater. Do not wash absorbent material down a floor drain or into a storm sewer.

Locate emergency spill containment and cleanup kit(s) in high potential spill areas. The contents of the kit shall be appropriate for the type and quantities of chemical liquids stored at the facility.

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5. References

Permit No. WA0031411, Effective Date: July 1, 2016.

Ecology Fact Sheet for NPDES Permit No. WA0031411, Effective Date: July 1, 2016.

Guidance Manual for Preparing/Updating a Stormwater Pollution Prevention Plan for Industrial Facilities (Ecology, April 2004).

Stormwater Management Manual for Western Washington (Ecology, February 2005).

6. Modification History

Revision Date

0. First submittal under Permit No. WA0031411 with Effective Date of July 1, 2016 August 30, 2016

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