environmental compliance, pollution prevention and self

Environmental Compliance,Pollution Prevention, and

Self-Assessment Guidefor the

Marina Industry

March 2003

New York State Department of Environmental ConservationPollution Prevention Unit

George E. Pataki, Governor Erin Crotty, Commissioner

TABLE OF CONTENTS

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Pollution Prevention and the Marina Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Invasive Species Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Marine Vessel Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Environmental Self-Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9General Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10General Operating Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Materials Handling, Inventory Control and Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Spill and Leak Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Parts Cleaning and Degreasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Shop Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18Air Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Permits and Registration - 6 NYCRR Part 201 . . . . . . . . . . . . . . . . . . . . . . . . . . 19Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Minor Facility Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20State Facility Permit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Title V Facility Permit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21General Process Emission Sources- 6 NYCRR Part 212 . . . . . . . . . . . . 22Solvent Metal Cleaning Process- 6 NYCRR Part 226 . . . . . . . . . . . . . . . 22Surface Coating Operations- 6 NYCRR Part 228 . . . . . . . . . . . . . . . . . . 23Record Keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

How To Calculate Your VOC Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Part 230- Gas Dispensing Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Water Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Can You Treat Or Recycle Your Wastewater? . . . . . . . . . . . . . . . . . . . . . . . . . . 26Wastewater Discharge Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Permitting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27Nonpoint Source Pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Stormwater Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Hazardous Waste Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Hazardous Waste Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Hazardous Waste Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Conditionally Exempt Small Quantity Generator . . . . . . . . . . . . . . . . . . 32Small Quantity Generator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Large Quantity Generator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Universal Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36Proper Handling and Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37Lamp Crushers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Freshwater Wetlands Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38Permit Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38Permitting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Protection of Waters- Article 15, Title 5 of ECL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Protection of Waters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Typical Marina Projects Requiring DEC Permits . . . . . . . . . . . . . . . . . . . . . . . . 41DEC Permit Application Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Other Agencies That May Be Involved With Regulations of Marinas . . . . . . . . 42

Solid Waste Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43Bulk Storage Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Storage Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45Hazardous Substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Regulatory Deadlines and Facility Upgrade . . . . . . . . . . . . . . . . . . . . . . 46Secondary Containment and Transfer Stations . . . . . . . . . . . . . . . . . . . . 46Spill Prevention Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Petroleum Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46When To Report A Spill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

Pesticides Management Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49What Are Pesticides? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49Pesticide Product Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49Pesticide Applicator Certification and Business Registration . . . . . . . . . . . . . . . 49Boat Owners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50Pesticide Use Safety And Personal Protection . . . . . . . . . . . . . . . . . . . . . . . . . . 50Aquatic Permits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50Integrated Pest Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51Pesticide Reporting Law And Record Keeping . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Waste Stream Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Abrasive and Alkaline Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Regulatory Requirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Absorbents and Floor Dry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Burn Barrels and Open Burning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Coating Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53Regulatory Requirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Floor Drains and Wastewater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Fluorescent Bulbs and Other Hazardous Lamps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Fuel Filters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Gasoline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Lead Acid Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Paint Scrapings and Abrasive Blast Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Parts Cleaning and Degreasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57Types of Parts Washers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

Solvent Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Aqueous Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Semi-Aqueous Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60Ultrasonic Cleaners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60Electrocleaning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

Solvent Distillation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

Shop Towels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

Spray Painting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

Used Electronics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Used Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Used Oil Storage Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63Transporting Used Oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64Used Oil Filters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Used Oil Space Heaters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Some Commonly Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

Resource Guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69New York State Department of Environmental Conservation . . . . . . . . . . . . . . . . . . . . 69NYSDEC Regional Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70State and Local Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71Federal Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72New York State Permitted Household Hazardous Waste Facilities . . . . . . . . . . . . . . . . 73

Trade Associations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74Resources on the Internet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

Green Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77Green Products Websites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79Non-Toxic Cleaning Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

Environmental Compliance, Pollution Prevention, and March 2003Self-Assessment Guide for the Marina Industry 1

INTRODUCTION

This environmental compliance guide(may also be referred to as a manual) is thefifth in a series of industry-specific guides thathas been developed by DEC’s PollutionPrevention Unit to assist businesses in NewYork State with environmental regulations,better waste management and wasteminimization methods. It was developed as asupplement to the Environmental Complianceand Pollution Prevention Guide for SmallQuantity Generators (SQG) manual, which isintended for any small and medium-sizebusiness that generates hazardous waste.

The purpose of this document is toprovide guidance to marina operatorsregarding the proper management of wastesthat are generated at marinas and yacht clubs.This guide describes some of theenvironmental issues that affect the marinaindustry. For the purposes of this manual, themarina industry shall include marinas andyacht clubs.

This guide specifically addresses wastegenerated by marinas and includes a self-assessment checklist that is intended to helpyour business achieve the maximumperformance from your day-to-day operationas well as prevent pollution and identifyopportunities for additional pollutionprevention measures.

For the most part, smaller businesses tryto comply with applicable regulations and arewilling to implement pollution preventionmeasures. In an effort to assist the marinaindustry, this guide provides information onhow to properly manage wastes that aregenerated at these facilities. This guide isdivided into sections:

# An overview of the marina industry,self-assessment, and general bestmanagement practices.

# A summary of DEC regulations as theypertain to the marina industry.

# Pollution prevention options for themarina industry

# Identification and management of wastestreams generated by the marinaindustry and best management practicefor each waste stream mentioned.

# Resource guides and references that willassist the marina industry with namesand addresses of technical assistanceproviders.

Preventing waste is better than having tomanage it. If your facility generates lesswaste, you will have less waste to manage anddispose of, resulting in lower disposal costs. Ifyour business generates less waste, youreduce your risk of spills and discharges thatcan contaminate the environment and reduceyour liability risk.

When you and your employeesfamiliarize yourselves with this complianceguide, your marina should have a competitiveadvantage by knowing the regulations and thelatest pollution prevention techniques. Keepthis manual where your employees can referto it as needed.


Pollution Prevention and the Marina IndustryNew York State has over 800 public and

private commercial marinas located along its697 miles of coastline, 52,000 miles of riversand 790,782 acres of lakes. Recreationalboating has become an increasingly popularuse of New York’s waterways.Approximately 458,100 boats are registered inNew York State (based on New York StateOffice of Parks, Recreation and HistoricPreservation 1996 data).

Marinas, yacht/boat clubs, and privatedockage areas can have significant impacts onthe concentrations of pollutants that enter thesurface waters within the general vicinity ofthe docking facilities. Many of thesesubstances settle in the bottom sediments, oraccumulate in the tissues of aquaticorganisms, degrade water quality, are toxic toaquatic life and pose a threat to human health.

With over 800 marinas in New York,there is the potential to cause a significantimpact on water quality during the operationand maintenance of these marinas. Majorpollutants of concern include petroleumhydrocarbons, lead, arsenic, zinc, iron,chromium, copper, tin, and woodpreservatives. These pollutants are generatedduring the operation and maintenance ofmarinas during boat painting, pesticideapplication, wood preservation, and fueling.Other pollutants can be generated throughactivities such as boat washing, storm waterrunoff, sewage runoff, dredging, and solidwaste disposal.

Marinas, yacht/boat clubs, and privatedocking areas are located adjacent to thewater where there may be only minimalbuffering during the release of chemicals orpollutants to the waterways. Therefore, it isimportant for marina operators and boatowners to take steps to prevent or minimize

the introduction of these pollutants to thewaterways. Adverse environmental impactsmay result from pollutants discharged fromboats, transported by storm water generatedfrom boat maintenance activities and from thephysical alteration of habitat duringconstruction activities.

The waste products generated bymarinas can pose significant environmentalconcerns during routine boat maintenance andnormal operation of motorized boats or crafts.Air contaminants, wastewater, and hazardouswaste issues must be observed and understoodby the marina industry, since some of theoperations generate corrosive, ignitable, toxic,or listed hazardous wastes. Operations thatcan generate air emissions, water pollution,and hazardous wastes include:

# Degreasing# De-rusting# Painting# Scraping# Fueling# Pump out# Boat maintenance# Grounds maintenance

There is a growing need for NewYork’s marina industry to understand andcomply with environmental regulations inorder to avoid enforcement actions and/orfines as well as potential harm to humanhealth and the environment. We should all doour part to properly manage the wastes thatare generated so that our air, water, and landcan remain clean.


DEC is promoting pollution preventionbecause it is often the most cost-effectiveoption to reduce pollution, as well as theenvironmental and health risks associatedwith pollution. The term pollution prevention(P2) refers to the elimination or reduction involume or toxicity of waste prior togeneration or prior to recycling, treatment orrelease to the environment. Even businessesthat do a good job of managing their materialsand wastes can end up spending largeamounts of money, time, and other resourceson environmental compliance. Pollutionprevention provides a means of meeting, andpossibly reducing a business’s environmentalcompliance requirements, while also savingmoney and improving its economiccompetitiveness. It is a proactive, “common-sense” approach to environmentalmanagement. By reducing, or eliminating, thegeneration of pollution in the first place, abusiness can save itself valuable resources.Pollution prevention can also be referred to aswaste reduction, waste minimization, orsource reduction. An effective pollutionprevention program can:

# Reduce the risk of criminal and civilliability;

# Reduce your operating costs;# Improve employee morale, participation,

and safety;# Enhance your company’s image in the

community;# Protect the public health and the

environment.In most cases, pollution prevention does

not involve expensive and “high-tech” processchanges. Many pollution prevention optionsfor marinas are simple and of minimal cost.

The best way to reduce pollution is toprevent it in the first place. Some companieshave implemented pollution preventiontechniques that improve efficiency and

increase profits while at the same timeminimize environmental impacts. This can bedone in many ways, such as reducing materialinputs, improving management practices, andemploying substitutes for toxic chemicals.Some smaller facilities are able to actually getbelow regulatory thresholds just by practicingsome simple pollution prevention strategies.

Waste segregation (separation orpreparation) involves avoiding the mixture ofdifferent types of wastes and avoiding themixture of hazardous wastes withnonhazardous wastes.

The following is a list of some generalpollution prevention methods can use tominimize waste at your facility.

Implementing a successful housekeepingprogram, as a rule, requires little or no capitalinvestment. Keep in mind that substantialsavings will not be achieved if routinesurveillance procedures are not implemented.Here are some housekeeping methods you cantry at your facility:

# Always obtain the material safety datasheets (MSDS) from your supplier orvendor for any chemical you use in yourshop. They provide specific informationabout the material.

# Inspect all shipments and return allunacceptable or damaged materials;especially those items that couldbecome hazardous wastes once they aresigned for.

# Practice preventive maintenance ofequipment.

# Cover solvent tanks when not in use toreduce evaporation.

Best Management Practices


Figure 8 Employees at this facility know that labelingand record keeping of hazardous materials areimportant steps in maintaining a good pollutionprevention program.

# Improve your purchasing and inventorymethods to ensure that materials do notexceed shelf life. Date all raw materialsand chemicals and use the first-in, first-out method of inventory control.Expired and outdated materials thatcan’t be used create waste.

# Turn off electrical equipment, such aslights and copiers, when not in use.

# Train employees in all areas, especiallyin chemical handling and spill response.

# Segregate hazardous from nonhazardouswastes.

# Use high efficiency fans, blowers, andfilters (about 50 percent efficient) atyour facility. Most fan filters in use areonly 10-20 percent energy efficient. Acentrifugal blower/motor can be up to25 to 30 percent efficient, and someother units are higher.

# Repair leaks around processingequipment (e.g., tanks, valves, pumpseals, transfer lines, heating coils).Losses of two gallons per hour canoccur through leaking pump seals alone.

# Install anti-siphon devices equippedwith self-closing valves on inlet waterlines where warranted.

# Inspect tank and tank liners periodicallyto avoid failures that might severelyoverload the waste treatment system.

# Use dry clean-up, where possible,instead of flooding with water.

# Install drip trays and splash guardswhere required.

Remember, the first step in establishing apollution prevention program at your facilityis to implement employee awareness. Oneway this can be achieved is by offeringtraining sessions on regulatory complianceand waste minimization so that youremployees can familiarize themselves with theproper waste management strategies.

Even though your business may generatea small amount of waste, keep in mind thatthere are thousands of businesses that generatea small amount. Together these businessesgenerate a large amount of waste that must bemanaged properly.

All hazardous waste generators, exceptconditionally exempt small quantitygenerators (CESQGs), are required tomanifest their hazardous waste as requiredunder the Environmental Conservation Law(ECL) 27-0907. These generators must sign acertification on the manifest form that, “thegenerator of hazardous waste has in place aprogram to reduce the volume or quantity oftoxicity of such waste to the degreedetermined by the generator to beeconomically practical.” A good source ofguidance is the Hazardous Waste ReductionPlan - Guidance Document, available bycontacting the Bureau of Hazardous WasteManagement in DEC’s Division of Solid andHazardous Materials.


(From www.protectyourwaters.net)

Eurasian Watermilfoil

Water Chestnut

Although there are no statewideregulations that require marinas to cleanrecreational water vehicles, DEC would liketo see marina operators and owners of watercraft use good management practices toprevent the spread of invasive species.

Aquatic Nuisance Species (ANS) aredefined as: “nonindigenous species thatthreatens the diversity or abundance of nativespecies or the ecological stability of infestedwaters, or commercial, agricultural,aquacultural, or recreational activitiesdependent upon such waters.” An invasivespecies is a plant or animal that, whenintroduced into a new habitat, expands rapidlyto the extent that it crowds out the existingnative community.

Many invasive ANS have the potentialto impact both boats and marinas that supportthem. Two excellent examples of invasive

ANS are Eurasianwatermilfoil andwater chestnut. Bothplants have thec a p a b i l i t y o fgrowing in thick,dense beds that cani n t e r f e r e w i t hboating and relatedactivities such asf i s h i n g a n dwaterskiing. Theseplants should be

important to marinas for two reasons. First, ifthe water body on which a marina is locatedbecomes infested with either or both of theplants, the quality of the boating experiencewill be diminished, and as a result, thenumber of boaters on the water using the marina is likely to decrease. Secondly, boats

and boat launch sites are a primary means andlocation for introducing these plants into awater body.

Eurasian watermilfoil is spreadprimarily by fragmentation. As boats gothrough the water milfoil beds, fragmentsbreak off and many become attached to theboat and motor. Also, floating fragments canget caught on trailers as boats are launched ortaken out of the water. If those loosefragments are not removed before the boat islaunched in a different water body, they canbe deposited in an uninfested water where thefragments could grow into a new plant,

thereby introducingthe plant into a newwater and spreadingthe problem.

Water chestnut is notas easy to spread, butc a n a l s o b etransported into newwaters by boats.

Invasive Species

http://www.protectyourwaters.net


Zebra Mussel

The seeds, or nuts of the water chestnutcontain four spikes that can get caught onb o a t s o r o nm o t o r s ,particularly if theboat had run intos o f t , s h a l l o wmuddy sediments.Like the watermilfoil fragments,the nuts cans i m i l a r l y b edropped off intoan uninfes tedwater.

R e c e n tstudies have shown that zebra mussels arealso commonly spread by “hitchhiking” onclumps of vegetation that get caught on boatsand/or boat trailers. Zebra mussels can causeseveral problems for marinas. They canaccumulate on docks, piers and pilings; blockwater intakes used by the marina; accumulateon buoys in such numbers that they causebuoys to sink; and their sharp shells can cutand injure the feet of anyone who walks onthem.

TIPS FOR REDUCING THESPREAD OF INVASIVE SPECIES

S Inspect boats before they are launchedto insure that all clumps of vegetationhave been removed and disposed ofwhere they cannot be washed into thewater before launching.

S Encourage boaters to clean allvegetation off of boats when leaving thewater.

S Provide trash cans and dumpsters for thedisposal of aquatic vegetation.

S Set up boat washing stations to sprayboats either before washing or uponremoval from the water. The wash watershould not be allowed to run off into thelake or river. Remove all trapped water(even small quantities) in livewells,bilges and engines and allow equipmentto completely dry.

S Flush engine cooling system with tapwater to remove zebra mussel larvae. Ifshells are allowed to grow inside, themotor will have to be taken apart toremove them.

S There are other invasive aquaticnuisance species other than the zebramussel and plants mentioned. SomeANS fish, like the round goby and theriver ruffe can cause significantproblems if released into new waters.

S Encourage fishermen to know their baitspecies, and to dispose of any unknownbaitfish away from the lake or river.

S Provide a place where leftover live baitcan be dumped, and encourage anglersnot to release unused bait into the water.

S Become familiar with exotic speciespresent in your area. You may see themoften and not realize it. Learn to knowwhat they look like, where they may befound, and report any sightings to yourlocal or state environmentalconservation office. Check and see ifthere are any known exotic species inlakes or rivers that you might visit.

S Report any fish that you can’t identify toyour local or state environmentalconservation office.

C h e c k o u t t h e w e b s i t e :www.protectyourwaters.net for more ideasabout what you or a marina owner/operatorshould know about aquatic nuisance species.

http://protectyourwaters.net


Currently, there are no statewidemandates or regulations requiring that marinasinstall a pump out or dump station at theirfacility, but there may be local laws whichrequire such installation. Many municipalitiesalso require permits for the installation and/oroperation of a pump out and/or dump station.Marina operators should contact their localgoverning agencies to determine all pertinentrequirements.

TECHNICAL GUIDELINES FORCONSTRUCTION

Pump out and dump stations should:

S provide an efficient means of removingsewage from boats and a means ofdisposing of that sewage in a safe andsanitary manner.

S include all the equipment, structures anddisposal facilities necessary toultimately discharge or dispose of boatsewage in an efficient, safe and sanitarymanner without causing an actual orpotential health hazard.

S include equipment for rinsing boatholding tanks.

S be operated and maintained to provideadequate service and be maintained tofunction as intended.

S be reliable, corrosion resistant, easy touse, neat, tidy and low maintenance.

S be conveniently located and easy to useto encourage boaters to use the facility.

All pumps should be:

S specifically designed for handlingsewage.

S safe, functional and efficient.S able to pump against the maximum head

developed by elevation changes and linelosses.

S able to transport flows out of theholding tank.

S properly sized. Pumps exceeding 45gallons per minute may cause tanks tocollapse.

S designed with a suction connection tothe boat which shall be a tight fit andadjustable by adapters to service boatdischarge connections.

Holding tanks:

S capacity should be determined based onseveral factors, including boat size anduse patterns.

S should be sized on a case-by-case basis.S should be designed and installed to meet

local regulations.

APPROPRIATE METHODS FORDISPOSAL OF VESSEL SEWAGE

Vessel sewage, know as sanitary waste,contains bacteria and viruses that can cause avariety of diseases such as hepatitus, typhoid,cholera, and acute gastroenteritis. In additionto bacteria and viruses, vessel sewage maycontain harmful nutrients and biologicaloxygen demand (BOD) loadings on the watersof the state.

Marine Vessel Waste PumpOut and Dump Stations


Publicly Owned Treatment WorksThe preferred method of disposal, wheneveravailable, is to discharge to a publicly ownedtreatment works (POTW). All approvals andpermits involved in this type of connection arethe responsibility of the applicant.

Holding TankIn the case of a stationary facility, thepumpout will be directly connected to theholding tank. In the case of a portable unit,there must be a connection provided forsanitary disposal of the waste. Discharge to aholding tank involves removal and transportof the waste by a person licensed to hauls e p t a g e wa s t e t o a mu n i c i p a lreceiving/treatment facility. The name of theperson contracted to do this must be providedat the time of the final inspection of thefacility. All approvals and permits are theresponsibility of the applicant. Sizing of theholding tank is dependent on the boat size anduse patterns at each facility and theanticipated frequency of waste removal fromthe tank.

On-site TreatmentThis includes discharge to a septic system oran on-site treatment plant. The marina ownermust be aware that the unique nature ofpumpout waste can often adversely affect theproper functioning of an on-site system andthe services of an engineer will be required todetermine if on-site treatment is feasible.(Septic systems and on-site systems aredesigned to handle only sewage and notindustrial or hazardous wastes.)

NOTE: New York State is a participant inthe Clean Vessel Act funding program thatprovides marina operators assistance withcosts of installing and renovating recreationalmarine vessel pumpout and dump stations.For further information on the Clean VesselAssistance Program, contact the New YorkState Environmental Facilities Corporation at1-800-882-9721, or visit the website atwww.nysefc.org.

http://www.nysefc.org


The following checklists are guidesdesigned to provide useful information andcan be used by anyone involved in the day-to-day operations associated with the marinaindustry. These checklists can be used toconduct routine self-assessments to identifypollution prevention opportunities.

Each section of the self-assessment thatis relevant to your business should bereviewed with the plant operator or facilitymanager who is most familiar with thatparticular part of the operation. Responses tothe questions should show whether or notcertain operations at your facility are incompliance with DEC regulations. In someinstances, methods such an operationalchange, product substitution or betterhousekeeping can help correct a violation.

This self-assessment is only one in aseries of steps that your business should taketo determine its regulatory compliance and toidentify suitable methods of waste reduction.For many small facilities, the self-assessmentwill likely be as useful as a thermometerwould be for a person with a fever: thesymptoms may be measured, but an expertopinion may be needed to diagnose theproblem and develop corrective measures.

Progressive facilities will use theenvironmental self-assessment to achieve twogoals: to evaluate current business practicesand to develop an ongoing program inpollution prevention.

Don't be discouraged by the sometimesdifficult process of identifying and addressingenvironmental problems. Over the long haul,the measurable benefits of conducting andresponding to regular environmentalself-assessments may include reductions foryour company in the following areas:

environmental hazards, enforcement actions,fines, insurance rates, waste handling costsand accidents. Other benefits may also includeimproved worker health, a better workenvironment, better relations with regulatoryagencies, improved employee morale,favorable publicity, and a stronger communityreputation for integrity.

You can use these checklists as guides todevelop your own checklists based on yourspecific facility needs and organization.Review each question carefully and check theappropriate box. A “Yes” answer indicatesthat your business or facility has incorporatedpollution prevention, waste reduction and/orrecycling measures into its day-to-dayactivities. A “No” or “Can’t Determine”answer indicates that an opportunity toprevent or reduce pollution may exist. Furtherreview is needed on the questions that receivea “No” or “Can’t Determine” response.

Use this self-assessment to create aworking list of pollution prevention andrecycling opportunities that should beexplored in greater detail. You are encouragedto consult with the DEC’s PollutionPrevention Unit located in Albany, theregional DEC Multimedia PollutionPrevention (M2P2) coordinator, tradeassociations, vendors or environmentalconsultants for additional information andassistance. See the “Resource Guide” of thismanual for a list of agencies and organizationsthat provide technical assistance on pollutionprevention.

Environmental Self-Assessment


GENERAL BEST MANAGEMENT PRACTICES

Pollution prevention is defined as reducing or eliminating the generation of waste. Thefollowing general pollution prevention measures and practices are intended to improve efficiency,increase profits, and minimize environmental impacts at your facility. Remember that pollutionprevention is a continuous process, so it should be included in your regular day-to-day operations.

Yes No NotApplicable

Can’tDetermine

Does your facility have a formal pollutionprevention policy and program?

Does your facility provide pollution preventiontraining for employees and encourage them toshare their ideas on how to reduce pollution?

Does your facility evaluate ways to reduce wastesproduced?

Does your facility consider alternative processesand chemicals to reduce toxic chemical use?

Does your facility take measures to reduceenergy consumption?

Does your facility have an environmentalassessment program to review design of newprocesses or tools for the purpose of identifyingand incorporating pollution preventiontechniques?

Do you work with your supply vendor to findnon-toxic or less toxic alternative products thatwork for your processes?

Do you re-evaluate your operation on a regularbasis to find new ways to reduce pollution?

Does your facility have methods to track theeffectiveness of your pollution preventionprogram?


GENERAL OPERATING PROCEDURES

Boat maintenance, gas pumping, waste handling and storage, and the release of chemicals intosurface waters should all be part of your marina’s day-to-day general operating procedures. Yourboat maintenance and gas pumping operations can generate a significant amount of hazardous wasteand can create potential environmental and health risks. By reviewing your operations on a routinebasis you can sometimes result in operational changes that can result in pollution prevention andsavings at your facility.


Can’tDetermine

Have your employees been trained to handle allwastes generated at your facility?

Have you designated any employee tosupervise your waste management program?

Does your facility maintain material safety datasheets (MSDS)?

Has your facility replaced hazardous solventcleaning processes with aqueous or less toxiccleaning processes?

Does your facility practice a preventativeinspection and maintenance program for allequipment?

Are all your floor drains connected to a publicsewer system or a holding tank?

Is your marina located near any wetlands?

Have you obtained all the necessary DECpermits necessary to operate and/or to do anyconstruction (especially near streams) at yourmarina.

If any employee is applying a pesticide orherbicide, are they licensed by DEC?

Has your marina initiated a program to preventvessel sewage from entering the waters?

Has your marina initiated a program to preventthe spread of invasive species?


MATERIAL HANDLING, INVENTORY CONTROL & STORAGE

To reduce waste and disposal costs, facility managers should insure there is a system inplace to keep track of the purchase, handling, storage and inventory of materials. The overpurchasing and improper storage of chemicals can result in significant waste generation.


Can’tDetermine

Have the employees responsible for purchasingsupplies at your facility been trained to manageinventory and keep accurate records of allchemicals used?

Does your facility keep chemical inventories toa minimum (keep only as much chemical supplyon site as needed for current production) andpurchase chemicals in the smallest quantitiespractical?

Does your facility use materials based onproduct and receipt dates (first in, first out)?

Have your employees been trained to handle alltypes of packages and chemicals received?

Does your facility limit access to chemicalsupplies?

Do you store all hazardous waste in an arealabeled as “hazardous waste storage area”?

Do you date all drums or containers storingwastes to properly identify the date ofgeneration? (Not required by CESQG’s)

Do you store all materials and wastes within thebuilding or in a covered storage building at yourfacility?

Does your facility store each of its wastes (oil,antifreeze, solvents, paints, gasoline) in separatecontainers?

Does your shop store used oil in tanks or closedcontainers that are clearly marked “Used Oil”?


SPILL AND LEAK PREVENTION

Spills and leaks can be reduced by making routine inspections of the areas that have the potentialto cause leaks or spills. A reduction in spills and leaks can save your facility money in lostsupplies and clean-up expenses.


Can’tDetermine

Does your materials storage area have a spillcontainment and collection system?

Does your facility have a leak detection systemfor any aboveground/underground tanks?

Has your facility installed overflow alarms tokeep tank contents from spilling over?

Does your facility use a “no-spill” fuel catcherwhen pumping gasoline into boats?

Do you cover all supply and waste containerswhen not in use to reduce the opportunity forspills and evaporation?

Does your facility use spouts, funnels and drippans to catch spills during the transfer ofmaterials?

Have your employees been trained in spillprevention and reporting requirements?

Is there a spill kit available near your gas pumpsor in other important areas of your marina?

Have you checked to see if any of your tanksneed to be registered?


WASTE MANAGEMENT

Maintenance and repair can generate waste such as: oil and filters, antifreeze, batteries,refrigerants, gasoline and diesel, solvents, paints and brushes, sand blast material, shop towels,speedy dry, absorbents, contaminated soil, pesticides, tires, sludges, fluorescent bulbs,wastewater, plastic shrink wrap, glue, epoxies, polyester resins, fish waste, used electronics, andair emissions.


Can’tDetermine

Do you require oil filters to hot drain for aminimum of 12 hours to collect all residual oilprior to disposal or recycling?

Are your oil filters crushed and sent forrecycling?

Does your shop dispose of transmission fluid,non-PCB dielectric fluid, gear oil, hydraulicfluid and cutting oil with its used oil?

Does your shop drain and save good antifreezefor reuse into other boats?

Do you store waste lead acid batteries on palletsin a well ventilated area that has an impermeablefloor and a berm to allow for spill collection andcontainment? If the area does not have a berm,are the batteries stored on pallets that have built-in spill containment or in closed containers?

Do you keep a neutralizing agent, such asbaking soda, near the battery storage area incase of leaks or spills?

Does your shop use CFC refrigerant recycling orrecovery equipment operated by certifiedtechnicians when servicing automobile airconditioning systems?

Are all of your employees aware that it is illegalto vent refrigerants to the atmosphere?

Is all painting done in an enclosed spray booth?


Has your shop investigated the use of paintswith lower volatility, lower metal concentrationsand a higher solids content?

Do you require that the spray guns be calibratedon a regular basis?

Does your shop use more efficient paint transferequipment such as high-volume/ low-pressure orlow-volume/low-pressure spray guns?

Does your shop have fully enclosed stations forcleaning spray guns?

Do you use small diameter hoses whendispensing solvents for cleaning spray guns?

Has your shop calculated its VOC emissionsfrom your spray painting operation?

Does your shop have a policy of reusing clean-up solvent in the next compatible batch of paint?

Are your shop towels stored in a closed metalcontainer and free of excess liquids?

Do you recycle your shrink wrap material?

Do you recycle your fluorescent or othermercury containing lamps?

Do you recycle your used computers and otheroutdated electronic equipment?

Do you recycle your shrink wrap?

Do you need an air permit for your spraypainting operations?

Do you or your customers drain antifreeze(including biodegradable types) into the waterafter the winter season?

Do you or your customers wash their boats withanything other than plain water?

If you have a boat washing system, is itpermitted?


PARTS CLEANING AND DEGREASING


Can’tDetermine

Have you explored the use of citrus-based,detergent-based or a hot soap parts cleaningsystem to replace a solvent or caustic-basedsystem?

Are your employees encouraged/required tobrush dirty parts to remove caked-on solids andto improve cleaning efficiency?

Do your cleaning solvents have a flash point ofmore than 140 degrees F?

Do you require solvent cleaning tanks to becovered when not in use?

If you use nonhazardous parts washers have youtaken steps to prevent contamination and haveyou tested the liquid, sludge and filter forhazardous characteristics?

Do you use a parts washer with a built-indistillation unit?

Do you discharge used parts washer solvent intosink, drain, or the ground?


SHOP CLEANUP


Can’tDetermine

Is all maintenance performed in areas with nofloor drains, or where the floor drains havebeen sealed?

If your shop has floor drains are they connectedto an oil/water separator that discharges to amunicipal sewer system or a holding tank?

Are discharges into the sanitary sewers withinlimits established by the sewage treatmentplant?

Does your shop use brooms or other drymethods as the primary means of cleaning theshop floors?

If you clean the shop floors using water, do youuse a biodegradable detergent?

Are your employees required to wipe up smallspills as soon as they occur?

Does your shop send its dirty shop towels to acommercial laundry service for cleaning?

Does your shop periodically clean its floordrains and test the sludge to determine if it is ahazardous waste prior to disposal?

Is your shop’s oil/water separator serviced on aregular basis?


Regulations

If your marina has boilers, emergencygenerators, a spray painting booth, or adegreasing operation, you will probably haveto comply with some state and federal airregulations. The Clean Air Act (CAA)requires the phase-out of the production ofchlorofluorocarbons (CFCs) and several otherozone depleting chemicals.It also imposes controls onC F C - c o n t a i n i n gcompounds. This section ofthe manual summarizesthese air regulations as theydeal specifically with themarina industry.

As part of marina operations, volatileorganic compounds (VOCs) are emitted fromcertain solvents, adhesives, paint mixing,paint spraying, surface preparation, andequipment clean-up. Volatile chemicalsproduce vapors readily at room temperaturesand normal atmospheric pressure, and thesevapors escape easily from volatile liquidchemicals. All liquid organic chemicals areconsidered to be VOCs unless they arespecifically exempted from the definition bythe EPA. Common examples of VOCs includebenzene, toluene, and xylene.

Ground-level ozone, a major componentof “smog,” is formed in the atmosphere byreactions between VOC and oxides ofnitrogen (NOx) in the presence of sunlight.High levels of ground-level ozone canendanger public health and damage crops andforests. As a means to protect the publichealth and environment, both DEC and EPAregulate VOC emissions. Marina processessuch as paint spraying and fuel burning are

likely to emit VOCs and nitrogen dioxide.In addition to VOCs, acid fumes,

particulates, ammonia fumes, chlorinatedfluorocarbons (CFCs), organic vapors, andvapors from laquer areas may also be emitted.Many of these air emissions may be hazardousair pollutants (HAPs), which are often subjectto additional controls. To obtain a list ofHAPs, contact DEC’s Division of Air listed inthe resource section of this guide. To reducethe level of HAPs, EPA sets MaximumAchievable Control Technology (MACT)standards that control emissions of one ormore air toxics from a specific air pollutantsource such as chromium electroplating oranodizing operations.

EPA has also established nationalambient air quality standards to limit levels of“criteria pollutants.” The criteria pollutantsare: carbon monoxide, lead, nitrogen dioxide,particulate matter, ozone, and sulfur dioxide.Even though this industry is not a majorsource of ozone, it is a major source of VOCemissions that mix in the atmosphere to formozone and smog.

If you suspect that your marina mayhave any air emissions, you should be familiarwith both the state and federal regulations thatapply to the marina industry. Under Title 6 ofthe New York Codes, Rules and Regulations(6 NYCRR) the marina industry may have tocomply with:

# Part 201 (Permits and Registration),# Part 212 (General Process Emission

Sources),

Air Regulations


# Part 226 (Solvent Metal CleaningProcesses) also known as vapordegreasing, and

# Part 228 (Surface Coating Processes)

The following are some of the mostcommon chemicals that may be released in themarina industry:

AcetoneAmmoniaCarbon DioxideCarbon MonoxideChlorineEthylene GlycolGlycol EthersHazardous Air PollutantsHydrochloric AcidHydrogen ChlorideHydrogen FluorideHydrogen PeroxideIsopropyl AlcoholMethanolMethylene ChlorideMethyl Ethyl KetoneNitric AcidParticulatesPhosphoric AcidSulfur DioxideSulfuric AcidTolueneTrichloroethyleneVolatile Organic CompoundsXylene

The information in this section will helpyou determine if your marina will require anair permit or registration. The air permitprogram is regulated under Title 6 New YorkCodes, Rules, and Regulations, Part 201 (6NYCRR Part 201).

Your marina should identify all emissionsources and then calculate the potentialemissions from each source. After you havetotaled your potential emissions for eachpollutant from all sources, you will then beable to determine whether or not your marinaneeds a Title V Permit, State Facility Permit,or Facility Registration.

EXEMPTIONSYour marina will need to obtain a Minor

Facility Registration, State Facility Permit, ora Title V Permit unless every process at themarina is specifically exempt from Part 201.Some common exemptions that may apply tothe marina industry are:

# Surface coating and related operationsoutside the New York MetropolitanArea and Lower Orange County Areawhich use less than 25 gallons ofcoating materials and solvents permonth, and performs all abrasivecleaning and surface coating operationsin an enclosed building with emissionsthat are exhausted to emission controldevices. These would include abaghouse for abrasive cleaningoperations and a spray booth and dryfilters for surface coating operations.

# Powder coating operations.# Thermal packaging operations

including, but not limited to, therimagelabeling, blister packing, shrinkwrapping, shrink banding, and cartongluing.

# Many degreasing operations are exemptif they don’t use HAPs.

# Venting and exhaust systems forlaboratory operations.

Permits and Registration -Part 201


Regulations InformationAir permit requirements can be found in 6NYCRR Part 201, while the VOClimitations are provided in 6 NYCRR Parts226 and 228. Facilities should alsoaddress the federal requirements of 40CFR Part 63, Subparts N and T.

# Exhaust systems for paint mixing, fillingor sampling, and/or paint storage roomsor cabinets, provided the paints stored inthese locations are stored in closedcontainers when not in use.

# Exhaust systems for solvent transfer,filling or sampling, and/or paint storagerooms or cabinets, provided the solventsstored in these locations are stored inclosed containers when not in use.

# Degreasing units which exclusively usenon-hazardous air pollutant acids.

# Degreasing units which exclusively usecaustics (e.g., potassium hydroxide andsodium hydroxide).

# Solvent cleaning of parts and equipmentperformed exclusively by hand wipingor hand cleaning.

# Manual surface coating/paintingprocesses which exclusively usebrushes, rollers, or aerosol cans.

# Hand-held or manually operatedwelding, brazing, and solderingequipment.

If you need assistance in determiningwhether or not your facility is exempt fromPart 201 permitting, call the regional DEC airengineer located in your area. (See resourceguide section for phone numbers)

M I N O R F A C I L I T YREGISTRATION

Minor Facility Registration isdetermined, in part, by proximity to NewYork City. The following conditions apply tominor facility registration.

Facilities in the New York CityMetropolitan Area

The New York City Metropolitan Areaconsists of New York City, and the countiesof Westchester, Rockland, Nassau, andSuffolk.

To be eligible to register, a facility located inthe New York City Metropolitan Area mustmeet all of the following condition:

# Total actual annual VOC emissionsmust be less than 12.5 tons.

# Total actual annual emissions of anyindividual HAP must be less than 5 tons.

# Total actual annual HAP emissions mustbe less than 12.5 tons.

# Total actual emissions of allcontaminants must be less than half ofall “Major Source” thresholds.

Please note that these “actual annualemissions” limits apply to the rolling 12-month sum of emissions for all periods. TheMajor Source thresholds are found in 6NYCRR Part 201-2.1(b)(21).

Facilities Outside of the New YorkCity Metropolitan Area

To be eligible to register, a facility locatedoutside of the New York City MetropolitanArea must meet all of the followingconditions:


# Total actual annual VOC emissionsmust be less than 25 tons.

# Total actual annual emissions of anyindividual HAP must be less than 5 tons.

# Total actual annual HAP emissions mustbe less than 12.5 tons.

# Total actual emissions of allcontaminants must be less than all“Major Source” thresholds.

Please note that “annual” emissions arecomputed on a rolling 12 month basis at theend of each month of operation. The MajorSource thresholds are found in 6 NYCRR Part201-2.1(b)(21).

STATE FACILITY PERMITState Facility Permits are determined, in

part, by proximity to New York City. Thefollowing conditions apply to state facilitypermits.

Facilities in the New York CityMetropolitan Area

# Total actual annual VOC emissions aregreater than 12.5 tons, but less than 25tons.

# Total actual annual emissions of anyindividual HAP are less than 10 tons.

# Total actual HAP emissions are lessthan 25 tons.

# Total actual emissions of allcontaminants are less than the “MajorSource” threshold.

Please note that “annual” emissions arecomputed on a rolling 12 month basis at theend of each month of operation. The MajorSource thresholds are found in 6 NYCRR Part201-2.1(b)(21).

Facilities Outside of the New YorkCity Metropolitan Area

# Total actual annual VOC emissions aregreater than 25 tons, but less than 50tons.

# Total actual annual emissions of anyindividual HAP are less than 10 tons.

# Total actual HAP emissions are lessthan 25 tons.

Please note that “annual” emissions arecomputed on a rolling 12 month basis at theend of each month of operation. The MajorSource thresholds are found in 6NYCRR Part201-2.1(b)(21).

TITLE V FACILITY PERMITTitle V Facility permits are required for

all “Major Sources” in New York State. Thedefinition of Major Source is found in 6NYCRR Part 201-2.1(b)(21).

“Non-Major” sources subject to 40 CFRPart 63 Subpart N (halogenated solventcleaning machines) can obtain a registrationand may be deferred from Title V permittingin the future. These sources must submit aTitle V permit by December 9, 2005. Formore information on 40 CFR Part 63 SubpartN, see section on NESHAP, page 15, or callDEC, Division of Air, or the Small BusinessAssistance Program listed in Section V.

*The following rules override the conditionslisted above for Minor Facility Registrations,State Facility Permits, and Title V Permits:

# Any new facility that is in an industrialcategory to which a Federal New SourcePerformance Standard (NSPS) appliesand which has a potential to emit that isbelow the major source thresholds mustobtain a State Facility Permit, regardlessof location or quantity of emissionsfrom that facility.

# Any new facility that emits acontaminant listed as a hazardous airpollutant, excluding those facilities


subject to VOC Reasonably AvailableCont ro l Technology (RACT)requirements under Parts 226, 228, 229,230, or 233, must obtain a State FacilityPermit, regardless of location orquantity of emissions from that facility.

# Any facility that is subject to a DEC-approved variance from therequirements of a State VOC RACTregulation must obtain a State FacilityPermit, regardless of location orquantity of emissions from that facility.

# Any facility that is subject to a NationalEmission Standard for Hazardous AirPollutant (40 CFR Part 63) must obtaina Title V Permit, regardless of locationor quantity of emissions from thatfacility. However, “Non-Major”facilities that are subject to 40 CFR Part63 Subpart N have been deferred fromthe requirement to obtain a Title Vpermit. Such sources are not required tofile for a Title V Permit until December9, 2005. Please call the DEC Division ofAir Resources or the Small BusinessAssistance Program for more details.(See Resource Guide for phonenumbers).

GENERAL PROCESS EMISSIONSOURCES - PART 212

This is the DEC regulation that coversair toxics and determines how much control isneeded on your facility’s toxic air emissions.Before a permit is written, you must establishyour emission rate potential. This is themaximum rate at which a specified aircontaminant from an emission source wouldbe emitted to the outdoor atmosphere in theabsence of any control equipment. After yourEmission Rate Potential is established, thenDEC will apply a rating of A, B, C, or D toeach contaminant that is emitted at yourfacility. This rating (A being the most toxic) is

assigned to each contaminant in order toconsider the potential environmental effects ofan air contamination source on itssurroundings.

It should be noted that the Part 212system for using Emission Rate Potential andEnvironmental Ratings to determine controlrequirements is likely to be changed in anupcoming amendment to Part 212.

SOLVENT METAL CLEANINGPROCESSES - PART 226

When cleaning or degreasing with aVOC solvent in a solvent cleaning machine,you are subject to Part 226 if your facilityuses a conveyorized degreaser greater than 22square feet of air/vapor interface; or an open-top vapor degreaser greater than 11 squarefeet of open area; or cold cleaning degreasing.

Chlorofluorocarbons (CFCs) werecommonly used as a cleaning solvent, butTitle VI of the federal regulations prohibitsthe production and importation of CFCs afterJanuary 1, 1996, except for some essentialuses. As long as your facility still has anexisting supply of CFCs, it can still use them.Many marinas are now using mineral spiritsor other solvents that contain no CFCs.

Solvent cleaning processes utilizing1,1,1 trichloroethane (methyl chloroform),and methylene chloride are specificallyexempt from Part 226. However, thesesolvents are still regulated by the NationalEmissions Standards for Hazardous AirPollutants (NESHAP) federal standard forsolvent cleaning machines. Perchloroethyleneis also exempt from Part 226 because EPAdelisted it as a VOC.

Your facility can not conduct solventcleaning operations unless:


# Solvent is stored in covered containersand waste solvent is transferred ordisposed of in such a manner that lessthan 20 percent of the waste solvent (byweight) can evaporate into theatmosphere.

# Equipment used in solvent metalcleaning is maintained to minimizeleaks and fugitive emissions.

# Equipment used in solvent metalcleaning displays a conspicuoussummary of proper operating proceduresconsistent with minimizing emissions ofVOCs.

# Equipment covers areclosed when the solventmetal cleaning unit is not inservice.

# A record of solventconsumption is maintainedfor each year and madeavailable to DEC uponrequest.

SURFACE COATING PROCESS,INCLUDING METAL PAINTINGOPERATIONS - PART 228

If your facility has a surface coatingprocess (metal painting and coatingoperations), then your facility must limit VOCemissions from all subject surface coatingprocesses in order to comply with the VOClimits found in Part 228. Compliancestrategies include high solids coating,ultraviolet coating, waterborne coating, andpowder coating systems.

If low VOC coatings are not available toyour facility, you can comply with Part 228by installing VOC control equipment, such asthermal oxidizers or carbon adsorption units.

The location of your facility and theamount of your VOC emissions willdetermine if you are subject to Part 228:

# If your facility is located in the NewYork City Metropolitan Area, regardlessof its annual potential to emit (PTE)VOCs, you must comply with Part 228.A facility’s PTE is the maximumcapacity to emit any regulated airpollutant under its physical operationaldesign. Physical operational limits, suchas air pollution control equipmentand/or restrictions on the hours ofoperation, or on the type or amount ofmaterial processed, can be included inthe design only if the limitation is partof a federally enforceable permitcondition.

# If your facility is located in the LowerOrange County Area and coats productsincluded in Table 1 of Part 228 and hasa PTE $10 tons VOC/year, or coatsproducts included in Table 2 of Part 228and has a PTE $25 tons VOC/year, youare subject to Part 228.

# If your facility is outside the New YorkCity Metropolitan Area or the LowerOrange County Metropolitan Area andcoats products included in Table 1 ofPart 228 and has a PTE $10 tonsVOC/year, or coats products included inTable 2 of Part 228 and has a PTE $50tons VOC/year, you are subject to Part228.

RECORD KEEPINGEven if your facility is exempt from

minor facility registration or air permittingrequirements, you should still maintainrecords of your VOC emission rates, even ifyou use fewer than 25 gallons per month. Bykeeping these records, you will:

# Show proof of compliance withapplicable DEC air requirements.

# Be able to determine if your facilityneeds any registrations or permits.


# Be prepared to provide information toany Regional DEC inspectors if, andwhen, they call to visit your shop.

# Help your facility toward implementinga pollution prevention program.

One of the easiest ways to keep recordsof your VOC emissions is by keeping yourpurchase order invoices for all the paints,lacquers, solvents, or additives used by yourfacility. Don’t forget to obtain a copy of theMSDS for each of the materials that youpurchase. If requested, most manufacturerswill fax or mail copies of MSDSs within a dayor two.

In order to determine what type ofregistration or permit your facility requires,you will need to know your total VOCemissions. To calculate your VOC emissions,you need to know your total annual usage ofmaterials (e.g., paints, lacquers, makeupsolvents, cleanup solvents, etc.). As discussedin the previous section, this information canbe obtained from your purchase orders. Also,if any other additives or solvents are used inyour shop that contain VOCs, such asisopropyl alcohol, the emissions from thesematerials should be accounted for in yourcalculations.

VOC emissions are equal to the annualusage rate of the materials applied, times theVOC content at the time of application. Tocalculate your VOC emissions,

Multiply your annual usage rate (gallons)of paints, lacquers, makeup solvents, andcleanup solvents by the density in poundsper gallon (from MSDS or technical datasheet) of paints, lacquers, makeup solvents,

and cleanup solvents by the weight fractionof VOCs in paints, lacquers, makeupsolvents, and cleanup solvents.

Note: Density = specific gravity X 8.34pounds/gallon. Weight fraction is the percentby weight divided by 100, which can beobtained from the MSDS or technical datasheet.

Example: Mike’s Marina uses 130 gallonsa year of coatings and lacquers, 52gallons/year of thinners, and 20 gallons/yearof cleanup solvents. The Material Safety DataSheets (MSDSs) list the VOC content at:coatings and lacquers, 5.0 pounds/gallon;thinners, 6.5 pounds/gallon; and cleanupsolvents, 7.0 pounds/gallon.

VOC = Annual Usage x VOCContent at Application

Paints and LacquersAnnual Usage = 130 gallons

VOC Content = 5.0 pounds/gallonVOC = (130 gallons/year) (5.0 pounds/gallon)

VOC = 650 pounds/year

ThinnersAnnual Usage = 52 gallons

VOC Content = 6.5 pounds/gallonVOC = (52 gallons/year) (6.5

pounds/gallon)VOC = 338 pounds/year

Cleanup SolventsAnnual Usage = 20 gallons

VOC Content = 7.0 pounds/gallonVOC = (20 gallons/year) (7.0

pounds/gallon)VOC = 140 pounds/year

How To Calculate Your VOCEmissions


Total VOC EmissionsMike’s Marina’s total annual VOC emissionsis 650 + 338 + 140 = 1,128 pounds.

In addition to the coatings, lacquers,thinners, and cleanup solvents, your marinamay use primers, multi-coating, pre-coat, andspecialty coatings. You should check theMSDS for the VOC content of thesematerials. Call the product manufacturer oryour distributor if you need copies of theseMSDSs.

If you are a marina with fewer than 100employees and need assistance in computingyour VOC emissions, finding out whatregistration/permits you need, or whether 6NYCRR Parts 212, 226, or 228 applies toyour facility, call the Small BusinessAssistance Program (SBAP) at (800) 780-7227. This non-regulatory program providesfree confidential technical assistance to helpsmall businesses achieve voluntarycompliance under the Clean Air Act.

PART 230 - GAS DISPENSINGFACILITIES

Air emissions from refueling operationsare addressed in 6 NYCRR Part 230 andEPA’s AP-42 Section 5.2.2.2 emission factors

for service stations. The factors in Table 5.2-7 can be used to calculate emissions from thefilling of the marina’s tank as well as theemissions from boat refueling. A storage tankwithout a drop tube would use the 11.5lb/1000 gallon throughput factor shown for“Splash filling”. A storage tank with a droptube would use the lower 7.3 lb/1000 gallonthroughput factor shown for “Submergedfilling”. If a station had a Stage I connectionon the tank, which allows the vapors to returnto the tank truck during delivery rather thanblowing out the vents, the 0.3 lb/1000 gallonthroughput factor would be appropriate. Since

Stage II is a vehicle refueling control strategythat is not used for marinas, the “uncontrolleddisplacement losses” factor of 11.0 lb/1000gallons throughput would be the refuelingfactor. We could also add in the 1.0 lb/1000gallons throughput “breathing and emptyingfactor” and the .7 lb/1000 gallon throughput“spillage” factor. We would end up with atotal emission factor of 7.3 + 11.0 + 1.0 +0 .7= 20.0 pounds of VOC emitted for eachmultiple of 1000 gallons of gasoline pumpedat a typical marina. The larger facilities mayfind that their gasoline refueling emissions aresignificant in comparison to their paintingoperations.

Does My Marina Need APart 230 Permit?

Part 230 does not apply as long as no vehiclesare refueled from the marina gasoline pumps.This means that the drop tube would not berequired in the storage tank under the airregulation, but most new tanks would beequipped with them as a pollution preventionand fuel conservation measure. In addition,neither Stage I or II would be required if novehicles are refueled at the facility.


Water Regulations

Most marinas are located on or near abody of water which means that there isalways the potential for contaminants to spillor leak into the waters of the State. Since gaspumping operations are often located ondocks, spills of petroleum products can occurif care is not taken during the dispensing ofgas into vessels. Wastes from marinas maycontain inorganic dissolved solids in the formof phosphates and sulfates, and organic wastesin the form of oils and greases.

Accidental spills, leaks, and drips ofpetroleum products can also contributesignificantly to effluent contamination.Usually tanks do not spring a leak that wouldallow the entire solution to leak awayundetected. However, a slow leak amountingto a solution loss of 10 to 20 gal/day could goundetected for weeks at some marinas.

CAN YOU TREAT OR RECYCLEYOUR WASTEWATER?

Wastewater treatment and recoveryprocesses can be considered treatment of ahazardous waste if the wastewater is a listedor characteristic hazardous waste. In order toavoid obtaining a permit under the hazardouswaste regulations, your process must meet oneof the exemptions found in 6 NYCRR Section373-1.1(d)(1). Processes that comply withcertain conditions are eligible for exemptionssuch as the wastewater treatment unit and therecycling exemptions. The wastewater itselfcould be excluded from being a hazardouswaste, such as the closed-loop exclusion.

WASTEWATER DISCHARGEREQUIREMENTS

Under the federal Clean Water Act, amarina operator can not discharge anypollutant to surface or ground waters of theState without a state pollutant dischargeelimination system (SPDES) permit. If yourfacility performs boat washing or has anystorm water runoff, you may be required toobtain either a general or a specific SPDESpermit. If your facility discharges process ornon-process wastewater directly to surfacewaters, you may be required to obtain a StatePollutant Discharge Elimination System(SPDES) permit. You are considered a directdischarger. If your facility discharges itsprocess wastewater to a sewer that flows to apublicly owned treatment works (POTW), youmay be required to meet pretreatmentstandards. You are considered an indirectdischarger.

Both direct and indirect dischargersmust meet effluent limits and conduct periodicmonitoring and reporting. Also, both directand indirect dischargers will be required topre-treat their wastewater to meet theirapplicable effluent limits.

PERMITTING REQUIREMENTSIf your facility discharges wastewater

directly into surface or groundwaters, thenyou are required to obtain a SPDES Permit.These permits are regulated under 6 NYCRRParts 750-758.


RememberBefore discharging oil

and grease, solvents,

acids, alkalides, or any

other wastes generated

at your facility to a

municipal sewer

system, check with

your local POTW.

A SPDES permit will list all pollutantsyour facility is discharging into surface orgroundwater that DEC determines necessaryto address. It may contain limits, action levelsor monitoring for each pollutant. Limitsapplied to your discharge will be the morestringent of either technology-based limits(sometimes referred to as best availabletechnology or BAT limits), water qualitylimits, or groundwater effluent standards.Water quality limits are calculated accordingto the classification and ambient standardsassigned to thespecific water bodyr e c e i v i n g t h ed i s c h a r g e . A l lsurface waters andgroundwaters inNYS are classifiedaccording to the bestusage, e.g., drinkingw a t e r o r f i s hpropagation.

T o m a k ecertain you arecomplying with yourpermit limits, youmay be required tos a m p l e y o u rdischarge and submit monitoring reports.Contact your regional DEC office forinformation on obtaining a SPDES permit. Alist of DEC regional offices can be found inresource guide section of this manual.

N O N P O I N T S O U R C EPOLLUTION

Pollutants that enter the water in stormwater runoff are referred to as nonpoint source(NPS) pollution. Even though recreationalboating and marinas are not considered byDEC to be a significant source of NPSpollutants, DEC does recognize that in someareas the increased number and size of

marinas does cause the potential for adverseimpacts to water quality.

Sources of non-point source pollutioninclude:# construction activities# septic system infiltration# agricultural runoff# marinas and recreational boating# highway and parking lot runoff

These sources of pollution couldintroduce contaminants such as nutrients,petroleum products, biological oxygendemand (BOD) loading, suspended solids, andbacteria into lakes, rivers, and other waterbodies of the state. Since marinas generatepollutants like heavy metals, hydrocarbons,solvents, antifreeze, acids/alkalis, nutrients,sediments, and bacteria, they should use bestmanagement practices to reduce or eliminatenonpoint source pollution.

For more information on nonpointsource management, you can obtain a copy ofthe manual, “Marina Operations for ExistingFacilities” from DEC’s Division of Water bycalling 518-402-8243.

Stormwater ManagementStormwater begins as rain or melting snowthat runs off fields or hard surfaces such aspaved roads, roofs and parking lots. As itflows through culverts, ditches or drains, thestormwater often picks up oils, litter, animalwastes, fertilizer, pesticides and eroded soils,sediment, heavy metals, or other materialscausing it to become polluted. When thisuntreated stormwater eventually flows intowaterways, it can impact water quality,leading to the closing of beaches and shellfishbeds, nuisance weed growth in lakes, thedestruction of aquatic habitats, and possibleflooding.


In 1987, under the Clean Water Act, EPAestablished a program to address storm waterdischarges associated with industrial activity.The term “storm water discharge associatedwith industrial activity” refers to a stormwater discharge from one of 11 categories ofindustrial activity defined in 40 CFR122.26(a)(9)(b)(14). Five of the categories aredefined by SIC codes, while the other six areidentified through narrative descriptions of theregulated industrial activity.

All marinas that are subject to the generalstorm water permit will fall into Category (xi)because they have a standard industrial codeof 34, and may fall into Category (i) becausethis category includes any facility, regardlessof size, that is subject to toxic pollutanteffluent guidelines.

Storm water permits are required when waterfrom your facility is conveyed to a surfacewater body. If your facility’s storm waterdischarge goes directly into a combined stormsewer and sanitary sewer system that conveysthe storm water to a POTW, then your facilitymay not need a general storm water permit.Check with your regional DEC office todetermine if your facility is exempt fromobtaining a storm water permit.

Storm water permits will help DEC recognizewhat wastes may eventually end up in thestate’s waterways. To this end, DEC issuesstorm water permits that cover dischargesfrom roads with drainage systems, catchbasins, curbs, gutters, ditches, man-madechannels, or storm drains, which are used forcollecting and conveying storm water directlyrelated to manufacturing, processing, or rawmaterial storage areas at industrial facilities.

DEC issues two types of storm water permits:individual permits or general permits. Anindividual permit is more complex and

requires substantial data collection andreporting as compared to a general permit.Your facility can apply for a general permit bythe following procedure:

# First, develop and implement a “StormWater Pollution Prevention Plan.” Todo this, you must obtain a copy of theSPDES General Permit for Storm WaterDischarges. You can get a copy bycalling your DEC regional office (seeresource guide). You can write theStorm Water Pollution Prevention Planor have a consultant prepare it. This plandoes not have to be submitted to DEC,but must remain on the premises in casea DEC inspector needs to review it.

# Second, submit a “Notice of Intent,Transfer, Termination” (NOITT) to:DEC, 625 Broadway, Albany, NY12233, Attention: Joe DiMura. Todownload a copy of the NOITT go to:www.dec.state.ny.us/website/dcs/permits/olpermits/noitt.pdf

General permits may require some typeof monitoring, depending on the type offacility. Usually, marina may only be requiredto do visual monitoring.

Information on storm water management canbe found on DEC’s website at:www.dec.state.ny.us/website/dow/mainpage.htm

B E S T M A N A G E M E N TPRACTICES

Here are some tips that could help youreduce the contaminants in your storm waterrunoff:

# Install water bars to divert off-site stormwater away from your marina,especially from maintenance and repair

http://www.dec.state.ny.us/website/dcs/permits/olpermits/noitt.pdf

http://www.dec.state.ny.us/website/dow/mainpage.htm


areas. Water bars are essentially speedbumps positioned to divert stormwater.

# Construct grass areas between themarina and the nearby surface water tofilter out any contaminants before theyare discharge to waters of the State.

# Other types of vegetation can effectivelyremove contaminants from stormwater.Even wetlands act as filter that removenutrients, hydrocarbons, and sedimentsfrom runoff.

# Perform all boat maintenance andpainting in an enclosed, roofed area. Ifany scrapings or boat maintenance hasto be performed outside, use a plastictarp to catch the contaminants. Please beaware that paint scrapings can not bethrown in the dumpster if they fail thetoxicity test. See section IV forregulatory requirements of paintscrapings.

# Don’t pour fluids into your septicsystem, into a dry well, on the ground,or in the trash.

# Cover all containers that are storedoutside to prevent any spillage onto theground.

# Install sand filters, holding tanks, oil-grit separators, or vortex concentratorchambers to improve storm waterquality before it is discharged.

# Try to do all your washing over a drainthat is connected to a sanitary sewer.

# Prohibit the use of soaps and detergentsby boat owners during boat washing.Instruct them to use plain water whenwashing their boats.

# When removing antifreeze from theboat’s engine or water system for thesummer season, do not empty theantifreeze on the ground or in the water.

# Try to have marina employees do allfueling. Make sure the pump’sautomatic shut-off is working properly.

# Always have a spill kit located close bythe fueling operations and make sure allemployees are trained in the use of spillcontainment and clean-up. The kitshould include: absorbent socks orbooms, absorbent pillows and pads, oildry, broom and shovel, disposal bags orother containers, safety goggles, plasticgloves.

# It is important to clean up spillspromptly and thoroughly.

Call DEC at (518) 402-8117 if you havequestions on the storm water managementprogram.


Hazardous Waste Regulations

The New York State hazardous wasteregulations are covered under 6 NYCRR Parts370-374 and 376 and apply to any marina thatgenerates hazardous waste. This includes, butis not limited to, facilities that conduct sometype of degreasing, fueling operations, boatmaintenance, or painting operations.

No matter what wasteyou dispose of, it is yourresponsibility to determinethe type and quantity ofhazardous waste you generateand properly manage it. Sincedisposal fees for hazardouswaste can be very expensive,it is in your best interest topractice good hazardouswaste management. Call theDEC Pollution Prevention Hotline toll free at1-800-462-6553 for assistance with managingyour hazardous waste. Refer to Section V formore information on technical assistanceproviders.

Here are some hazardous wastescommonly generated by the marina industry:

# Heavy metal wastes# Ignitable wastes# Solvent wastes# Toxic wastes# Still bottoms# Reactive wastes# Acids/bases# Sludges# Rags

H A Z A R D O U S W A S T EDETERMINATION

If you generate wastes at your facility,you should determine which are hazardous.As a good management practice, always keepnon-hazardous waste separate from yourhazardous waste. This will reduce or eliminatethe mixing and/or contamination of wastes,that could increase your disposal costs.

One way to make a hazardous wastedetermination is to see if your waste islisted in the New York Stateregulations, 6 NYCRR Part 371. Ifyour waste is listed, it is hazardous. Ifyour waste is listed in Part 371, it isautomatically hazardous waste. Evenif your waste is not listed, it wouldstill be a hazardous waste if it exhibitsone of the hazardous wastecharacteristic of ignitability,corrosivity, reactivity, or toxicity

found in 6 NYCRR Parts 371 and describedfurther below.

You can also apply your knowledge ofthe waste to determine if it exhibits ahazardous characteristic. You must have abasis for making this determination, such asmaterial safety data sheets (MSDSs) or past

Don’t ForgetAlways keep goodrecords of all the

hazardous waste yourfacility generates.

Reminder

If you do not have a copy of the manual

Environmental Compliance and Pollution

Prevention Guide for Small Quantity

Generators, you can get your copy by

calling DEC at 1 - 800 - 462-6553.


analytical results. MSDSs may containimportant information, such as ignitability(flashpoint), corrosivity, or reactivity forsubstances or chemicals you may use at yourfacility. Please note that MSDSs only describethe new product. During use, a non-hazardousproduct could become hazardous, e.g., bymixing or contamination.

As mentioned previously, if your wasteis listed in 6 NYCRR 371.4 (Hazardous WasteRegulations), then you know you mustmanage it as a hazardous waste. If, however,it is not listed, then your facility must make ahazardous waste determination on that waste.If your business generates hazardous waste,you should understand the term since it mayapply to some of the waste streams mentionedin Section III. You should read the DECmanual, Environmental Compliance andPollution Prevention Guide for SmallQuantity Generators, to familiarize yourselfwith the requirements and conditions forhazardous waste generators.

If you generate a waste at your facilitythat is not listed in 6 NYCRR Section 371.4,you must still determine if that waste ishazardous by any of the following fourcharacteristics: ignitability, corrosivity,reactivity, and toxicity.

IgnitabilityIf your liquid waste has a flashpoint of lessthan 140E F, it is hazardous. Examplesinclude: parts cleaners, paint solvents, wastekerosene, and waste gasoline.

CorrosivityIf your waste has a pH of 2.0 or lower, or apH of 12.5 or higher, it is hazardous.Examples include: lead-acid batteries, certainrust removers, caustic parts degreaser, andacid or alkaline baths or solutions.

ReactivityIf your waste is unstable and undergoesviolent chemical reaction spontaneously orreacts violently with air or water, it ishazardous.

ToxicityIf your waste is not ignitable, corrosive orreactive, then it might have to be tested fortoxicity according to the methods explained in6 NYCRR 371.3(e), or in the federalregulations, 40 CFR Part 261. Examplesinclude: certain painting wastes, paint boothfilters, used shop towels or rags, oily wastesother than used oil, oil absorbents, wastewatertreatment sludges, and rinse water.

A toxicity test is done by having arepresentative sample of the waste tested by acertified lab, where it is analyzed using atoxicity characteristic leaching procedure(TCLP). If the test exceeds any of theallowable standards listed in Table 1, page 33,then the waste is hazardous. For a copy ofcertified labs in New York State, call 1-800-462-6553.

A waste that exhibits one or more of theabove traits is a hazardous.

Did You Know?

As a CESQG, you can transportup to 220 pounds per month ofyour own waste to a Stateapproved facility.


H A Z A R D O U S W A S T ECATEGORIES

Once you have determined that yourbusiness generates hazardous waste, then it isnecessary to determine your hazardous wastecategory status. Depending on the quantityand type of waste generated, and the amountof waste stored, you will be in one of thefollowing categories: Conditionally ExemptSmall Quantity Generator (CESQG), SmallQuantity Generator (SQG), or Large QuantityGenerator (LQG).

This section does not discuss in detailthe requirements for the LQGs. LargeQuantity Generators are fully regulated under6 NYCRR Parts 370-374 and 376. LargeQuantity Generators can obtain a copy of theregulations by calling (518) 402-8730.

Conditionally Exempt SmallQuantity Generator

A conditionally exempt small quantitygenerator (CESQG):

# Generates no more than 220 pounds(approximately 26 gallons) of hazardouswaste per calendar month,

# Generates no more than 2.2 pounds ofacute hazardous waste per calendarmonth, and

# Stores no more than 2,200 pounds ofhazardous waste or 2.2 pounds of acutehazardous waste on site at any time.

If You Qualify as a CESQG, You Must:

# Identify your hazardous waste.# Comply with storage quantity limits.# Ensure proper treatment and/or disposal

of your waste.

CESQG’s can deliver up to 220 pounds(per month) of their hazardous waste to anoffsite treatment or disposal facility as longas they transport it to:

# A state or federally regulated hazardouswaste management treatment, storage ordisposal facility.

# A facility permitted by NYS to managemunicipal or industrial solid waste andauthorized to receive CESQG hazardouswaste.

# A facility that uses, reuses orlegitimately recycles the waste.

# A permitted household hazardous wastecollection facility that accepts CESQGwaste. See resource guide section of thismanual for a list of participatingmunicipalities.

If you elect not to deliver your own hazardouswaste, you must use a 6 NYCRR part 364permitted transporter.

Small Quantity GeneratorA small quantity generator (SQG):

# Generates between 220 pounds and2,200 pounds of hazardous waste percalendar month,

# Generates less than 2.2 pounds of acutehazardous waste per calendar month,and

# Stores less than 13,200 pounds ofhazardous waste or 2.2 pounds of acutehazardous waste on site at any time.


Table 1

Toxicity Characteristic Leaching Procedure (TCLP)The following are substances covered by the TCLP. The concentrations are not total amounts of the chemicalin the waste, but concentrations in the TCLP leachate after the specific test is carried out.

WasteCode

Substance CASNumber

TCLPConcentrationLimit (mg/l)

D004 Arsenic 7440-38-2 5.0

D005 Barium 7440-39-3 100.0

D006 Cadmium 7440-43-9 1.0

D007 Chromium 7440-47-3 5.0

D008 Lead 7439-92-1 5.0

D009 Mercury 7439-97-6 0.2

D010 Selenium 7782-49-2 1.0

D011 Silver 7440-22-4 5.0

D012 Endrin 72-20-8 0.02

D013 Lindane 58-89-9 0.4

D014 Methoxychlor 72-43-5 10.0

D015 Toxaphene 8001-35-2 0.5

D016 2,4-Dichlorophenoxyacetic acid 94-75-7 10.0

D017 2,4,5-Trichlorophenoxypro pionic acid 93-72-1 1.0

D018 Benzene 71-43-2 0.50

D019 Carbon Tetrachloride 56-23-5 0.50

D020 Chlordane 57-74-9 0.03

D021 Chlorobenzene 108-90-7 100.0

D022 Chloroform 67-66-3 6.0

D023 o-Cresol 95-48-7 200.0*

D024 m-Cresol 108-39-4 200.0*


D025 p-Cresol 106-44-5 200.0*

D026 Cresol ........... 200.0*

D027 1,4-Dichlorobenzene 106-46-7 7.5

D028 1,2-Dichloroethane 107-06-2 0.50

D029 1,1-Dichloroethylene 75-35-4 0.70

D030 2,4-Dinitrotoluene 121-14-2 0.13**

D031 Heptachlor (and its epoxide) 76-44-8 0.008

D032 Hexachlorobenzene 118-74-1 0.13**

D033 Hexachloro-1,3-Butadiene 87-68-3 0.5

D034 Hexachloroethane 67-72-1 3.0

D035 Methyl ethyl ketone 78-93-3 200.0

D036 Nitrobenzene 98-95-3 2.0

D037 Pentachlorophenol 87-86-5 100.0

D038 Pyridine 110-86-1 5.0**

D039 Tetrachloroethylene 127-18-4 0.7

D040 Trichloroethylene 79-01-06 0.5

D041 2,4,5-Trichlorophenol 95-95-4 400.0

D042 2,4,6-Trichlorophenol 88-06-2 2.0

D043 Vinyl Chloride 75-01-4 0.20

* If o-, m-, and p-Cresol concentrations cannot be differentiated, the total cresol (D026)concentration is used. The regulatory level of total cresol is 200.0 mg/l.

** Quantitation limit is greater than the calculated regulatory level. The quantitation limit,therefore, becomes the regulatory level.


A SQG Must Do The Following:

# Obtain an EPA Identification Number bycalling EPA at (212) 637-4106.

# Submit a completed hazardous wastemanifest form.

# Use a 6 NYCRR Part 364 permittedhazardous waste transporter.

# Limit on-site storage. Waste must beshipped within 180 days of accumulation(or 270 days, if the treatment, storage, ordisposal facility is greater than 200 milesaway).

# Follow emergency preparedness andresponse requirements.

# Adhere to land disposal restrictions.

Storing Your Hazardous Waste

# Keep the waste in aseparate storage areaw h i c h i s l a b e l e d“ H azardous Was t eStorage Area.”

# Label all containers.# Mark each container with

the date you begancollecting waste in thatcontainer.

# Use proper containment (pallets withbuilt-in spill containment or berms) incase of leaks.

# Keep containers closed when not in use.# Keep containers in good condition and

periodically inspect for leaks, cracks orrust.

#

For more information on small quantitygenerators, request a copy of the manual,Environmental Compliance and PollutionPrevention Guide for Small QuantityGenerators by calling 1-800-462-6553.

Large Quantity GeneratorIf you meet any of the following conditions,you are a large quantity generator:

# Generate more than 2,200 pounds ofhazardous waste per calendar month.

# Generate more than 2.2 pounds of acutehazardous waste per calendar month.

# Store more than 13,200 pounds ofhazardous waste on site at any time.

# Store more than 2.2 pounds of acutehazardous waste at any time.

By using good waste management andpollution prevention methods mentioned inthis manual, most marinas should not be alarge quantity generator. However, if yourmarina is a large quantity generator, youshould call the Division of Solid andHazardous Materials at (518) 402-8730 toobtain a copy of the regulations, or go theD E C w e b s i t e a t :http://www.dec.state.ny.us/website/dshm/regs/370parts.htm

Large quantity generators must obtain an EPAID number, store hazardous waste no morethan 90 days on site, manifest their waste,submit biennial reports to DEC, keep recordsat your site for 3 years, comply with landdisposal restrictions, and comply withexport/import requirements when shippingwaste out of the country.

UNIVERSAL WASTETo streamline the hazardous waste

regulations for wastes that are generated bylarge numbers of sources in relatively small

Did You Know?As a Small Quantity Generator, you cannottransport your own waste. You must use a 6 NYCRR Part 364 permitted transporter.

http://www.dec.state.ny.us/website/dshm/regs/370parts.htm


quantities, USEPA issued the Universal WasteRule in 1995. The universal waste regulationsgovern the collection and management ofwidely generated wastes. In NYS, thesecurrently include hazardous batteries,pesticides, thermostats, and lamps. Thesesregulations were designed to reduce theamount of hazardous waste items in themunicipal solid waste stream; encourage therecycling and proper disposal of somecommon hazardous wastes; and reduce theregulatory burden on the regulatedcommunity. Universal wastes are generated ina wide variety of settings includinghouseholds, schools, office buildings, andmedical facilities, in addition to the industrialsettings usually associated with hazardouswastes. Universal wastes include such itemsas hazardous batteries, hazardousmercury-containing thermostats, certainpesticides, and hazardous lamps. Althoughhandlers of universal wastes must meet lessstringent standards for storing, transporting,and collecting wastes, the wastes must complywith full hazardous waste requirements forfinal recycling, treatment, or disposal. Thisapproach removes these wastes frommunicipal landfills and incinerators, whichprovides stronger safeguards for public healthand the environment.

BatteriesBatteries included are nickel-cadmium(Ni-Cd), lithium, small sealed lead-acidbatteries, and batteries that exhibit hazardouswaste characteristics. These may be found inmany common items in the business andhome, including electronic equipment, mobiletelephones, portable computers, andemergency backup lighting.

Mercury ThermostatsMercury thermostats are located in manybuildings including offices, schools, industrialfacilities, and homes.

PesticidesAgricultural pesticides that are recalled undercertain conditions and unused pesticides thatare collected and managed as part of a wastepesticide collection program. Pesticides maybe unwanted for a number of reasons, such asbeing banned, obsolete, damaged or no longerneeded due to changes in cropping patterns orother factors.

Hazardous LampsExamples of common universal wastehazardous lamps include, but are not limitedto, fluorescent lights, high intensity discharge,neon, mercury vapor, high pressure sodium,and metal halide lamps. Many used lamps areconsidered hazardous wastes under theResource Conservation and Recovery Act(RCRA) because of the presence of mercuryor occasionally lead.

REQUIREMENTSIf your waste includes hazardous

batteries, pesticides, thermostats, or lamps,you must decide whether or not you willmanage them as universal waste. You maychoose between traditional hazardous wasteregulations or universal waste rule standards.However, flip-flopping between the two setsin order to avoid meeting requirements of oneor both sets of regulations is not allowed. Forexample, storage time limits exist for bothmanagement scenarios. Flip-flopping betweenregulations will not extend storage time.

If you decide to manage these wastesunder the traditional hazardous wasteregulations, you must count them indetermining whether you are a conditionally


exempt small quantity generator (CESQG), asmall quantity generator (SQG) or a largequantity generator (LQG). They must also bereported on the generator annual report if youare required to file an annual report. Universalwastes are not counted for the purpose ofdetermining generator category, and need notbe reported on your hazardous waste report.

PROPER HANDLING ANDSTORAGE

If your facility manages any of the abovementioned universal wastes at your site, thenyou are either a small quantity handler or alarge quantity handler of universal waste. Asmall quantity handler of universal waste isany facility that handles less than 5,000 kg(11,000 lbs) of total universal wastes on site atany time. Requirements include packaging ina way to minimize breakage; immediatelycleaning up any leaks or spills; employeetraining, and properly labeling containers. Alarge quantity handler of universal wastehandles 5,000 kg (11,000 lbs) or more of totaluniversal wastes on site at any time.Requirements include EPA notification;packaging in a way to minimize breakage;immediately cleaning up any leaks or spills;employee training, and properly labelingcontainers; and complying with recordkeeping and reporting requirements. Bothhandlers can store universal waste up toone year on site.

Universal waste transporters must meetapplicable DOT standards; comply withrecord keeping and reporting requirements;and comply with applicable requirements of 6NYCRR Part 364 if transporting more than500 lbs of total universal waste in anyshipment. Common carriers can transport upto 500 lbs of universal waste in any shipment.

Destination facilities must comply withall applicable requirements of 6 NYCRR Parts370 through 374-3 and 376, includingnotification of hazardous waste activity andobtaining a Part 373 hazardous waste permit,if applicable.

LAMP CRUSHERSLamps being managed under the

universal waste rule may not be crushed. Ifyou wish to crush your lamps, you will needto manage the lamps under the traditionalhazardous waste regulations. This will requirethat you count the weight of the lamps towarddetermining hazardous waste generatorcategory, and you will be required to meetapplicable generator, transporter and transferfacility standards. Crushing is considered aform of hazardous waste treatment, and underordinary hazardous waste generatorregulations, hazardous waste lamps may onlybe crushed if the process is exempt fromhazardous waste treatment regulations (6NYCRR 373-1.1(d)(1)). The commonexemptions that might be used are the on-sitetreatment by a conditionally exempt smallquantity generator; the first step of a recyclingprocess, if the lamps will be directed to amercury recycler; or the treatment in the tankor container in which the lamps are beingstored. Generators who wish to use one of thelatter two exemptions should seek specificguidance from the Technical DeterminationSection at (518) 402-8633. The crushed lampsare usually considered hazardous waste formercury, and sometimes for lead, and must behandled and disposed of via normal hazardouswaste requirements.


Freshwater Wetlands Regulations

Wetlands are known by names such asmarshes, swamps, bogs, and wet meadows.The Freshwater Wetlands Act identifieswetlands on the basis of vegetation becausecertain plants are good indicators of wet soilsover time. Typical wetland vegetation mayinclude wetland trees and shrubs, such aswillows and alders; emergent plants, such ascattails and sedges; aquatic plants, such aswater-lily; and bog mat vegetation, such assphagnum moss.

Wetlands are valuable to the people andto the health of the environment. Somefunctions and benefits that wetlands performare:

# Flood and storm water control. Theyabsorb, store, and slow down themovement of rain and melt water,minimizing flooding and stabilizingwater flow.

# Surface and groundwater protection.They often serve as groundwaterdischarge sites, maintaining base flow instreams and rivers and supporting pondsand lakes.

# Erosion control. They slow watervelocity and filter sediments, protectingreservoirs and navigational channels.

# Pollution treatment and nutrient. Theycleanse water by filtering out natural andmany man-made pollutants.

# Fish and wildlife habitat. They are one ofthe most productive habitats for feeding,nesting, spawning, resting and cover forfish and wildlife, including many rareand endangered species.

# Public enjoyment. They provide areas forrecreation, education, and research.

PERMIT EXEMPTIONSThe following activities either have been

exempted from regulation or are not regulatedbecause they will not substantially impair anyof the functions and benefits of freshwaterwetlands:

# Continuing with all existing activitiesdirectly associated with such use, exceptfor those activities covered by items 38-41 in 6 NYCRR Part 663, that does notinvolve expansion or significantalteration of existing use and does notaffect the wetland area.

# Establishing scenic, historic, wildlife,and scientific preserves, where nosignificant impairment of the wetland orits benefits is involved.

# Boating, hiking, swimming, camping,picnicking, and other similar non-motorized forms of outdoor activity,where no significant impairment of thewetland or its benefits is involved.

# Depositing or removing the naturalproducts of wetlands in the process ofrecreational or commercial fishing, shellfishing, agriculture, hunting or trapping,including the erection and maintenanceof temporary hides or blinds.

# Conducting educational or scientificresearch activities where no significantimpairment of the wetland or benefits isinvolved.

# Establishing walking trails where nosignificant impairment of the wetland orbenefits is involved.

# Establishing an individual recreationalmooring.

# Gathering fuel wood, except as coveredby items 22-24 of 6 NYCRR Part 663.


# Conducting an agriculture activity asdefined in 6 NYCRR section 663.2.

PERMITTINGIf your marina is a commercial facility

located within 100 feet of a designatedwetland that is 12.4 acres (5 hectares) orlarger, and performs construction (docks, boatstacking), dredging, gas storage, or pump-out,you may be required to obtain a Part 663wetlands permit. Below is a brief overview forsome of the activities that may require apermit. If your marina is involved with any ofthe following activities, you should contactyour DEC regional office to see if a permit isrequired.

Existing Structures and FacilitiesNormally, maintenance, repair, or restorationof existing facilities will not cause adverseimpacts to wetlands. This is not always truefor construction activities that are associatedwith such maintenance, repair, andrestoration, such as placing of access roads,staging areas, and utilities.

Operating Motor VehiclesIntense use of motor vehicles may impair anyof the several functions and benefits ofwetlands by introducing or increasingcontaminants, noise, or other forms ofpollution, or by removing or reducingvegetation and exposing soil and increasingerosion. Occasional use generally does notrequire permitting.

Draining, Filling, Grading,Clear-cutting, and Dredging

The draining of wetlands may lowergroundwater levels, may increase down-stream peak flows, and may decrease waterstorage capacity and downstream base flow. Itmay also cause changes in vegetation and

water temperature, increase stream bedscouring, and sediment deposition.

Filling decreases the number and size ofwetlands, thereby decreasing their ability tocollect runoff and prevent erosion andsediment deposition downstream.

Grading a wetland or adjacent area cansubstantially alter surface water drainage andflow patterns, may temporarily increaseerosion, and may eliminate fish and wildlifehabitat.

Clear-cutting removes the vegetative cover ofwetlands and may reduce their ability toabsorb water and serve as habitat. It can alsocause soil erosion.

Dredging or excavation may increase waterdepth and remove wetland vegetation, thusaltering the basic characteristics of thewetland. Fish and wildlife feeding orreproductive capacities may be altered.

Dams, Locks, and BulkheadsStructures of this type are usually indicativeof some form of development which maydisrupt human use or occupancy of thewetlands area. Generally speaking, docks builton piles are more compatible with thefunctions and benefits of wetlands than aredocks built on fill.

Dams alter normal flow patterns and oftenincrease water levels, thus eliminating oraltering the natural vegetation.

UtilitiesInstalling utilities in or adjacent to wetlandsmay cause problems when extensive clearingand construction of access or maintenanceroads occur.


Installing overhead lines could result inpermanent adverse aesthetic impact on thewetlands. Overhead power lines may alsoresult in higher bird mortality rates, eitherthrough collision or electrocution.

Pollution and PesticidesThe introduction of sewage effluent, runoff ofpesticides, or disposal of toxic substances intowetlands or adjacent areas may contaminateground and surface water with undesirablechemicals, nutrients, and organisms. Thepresence of pollutants or pesticides inwetlands or adjacent areas may increasemortality rate among fish and wildlife, altertheir behavior or reproductive capability, andadversely affect their value as a food source.Excessive nutrients alter vegetative cover, fishand wildlife distribution, and water potability.

BuildingsThe construction of buildings, accessoryroads, and parking areas can have severaleffects on wetlands. Roofs and paved areasshed rain which could result in more turbulentstream flow, more erosion and sedimentation,and higher water levels in surrounding areas,including nearby wetlands.

For a complete list of activities associatedwith each of the categories listed above,please refer to subdivision 663.4(d) of theFreshwater Wetlands Permit Requirements.


Protection of Waters - Article 15, Title 5 of the ECL

• Protection of Waters (Article 15, Title 5of the ECL)

• State 401 Water Quality Certification• Freshwater Wetlands (Article 24 of the

ECL) and• State Pollution Discharge Elimination

System (SPDES) (Article 17 of the ECL)

PROTECTION OF WATERS

• Docks and Moorings• Excavation and Fill in Navigable Waters• Disturbance of Protected Streams

Docks and Moorings Examples of exempt activities include:• Docks and other structures on State

owned lands for which a lease has beenobtained from the NYS Department ofGeneral Services.

• A docking facility for five or fewer boatsand a perimeter area of less than 4,000square feet.

• Mooring area for fewer than 10 boats.• Seasonal installation and removal of

floating docks.• Relocation, replacement, rearrangement

of floating docks and walkways withinthe established perimeter.

• Ordinary maintenance and repair of dockand mooring structures.

Excavation and Fillin Navigable Waters

• Applies to navigable waters inundated atmean high water.

• Applies to marshes, estuaries andwetlands that are adjacent to orcontiguous with navigable waters.

Disturbance of Protected Streams

• Applies to water bodies protected bywater quality standards

TYPICAL MARINA PROJECTSREQUIRING DEC PERMITS

• Bulkhead and breakwater installations,replacements and repairs

• Dredging• Shoreline stabilization• New dock construction

DEC PERMIT APPLICATIONREQUIREMENTS

• Joint Application for Permit• Location Map• SEQR Environmental Assessment Form• Coastal Consistency Assessment Form• Project Plans and Narrative Description

of the Work• Photographs of the work site

When submitting your permit application,it is important to include as much informationas possible about the project with your initialsubmission. There may be a requirement topublish a Notice of Complete Application inthe local newspaper.


Project Planning Guidance

S Try to apply early for permits.S Contact our office for information and

application forms.S There are Seasonal Environmental

Windows for work to be conducted in thewater.

S Avoid filling in the water to create moreland area.

S Bulkheads and shore protectionstructures should be designed to followthe existing shoreline or the existingbulkhead line.

Dredging Disposal Options

S Upland disposalS Corps of Engineers confined disposal

areas, usually used for contaminatedsediment disposal

S Upland disposal with beneficial usedetermination

S Do you have permission from the landowners where you wish to dispose ofsediment?

OTHER AGENCIES THAT MAYBE INVOLVED WITH THEREGULATION OF MARINAS

• U.S. Army Corps of Engineers • New York State Department of State• New York State Canal Corporation• New York State Office of Parks,

Recreation and Historic Preservation• U.S. Coast Guard.


Solid Waste Regulations

In 1988, the Solid WasteManagement Act put emphasis onwaste reduction, reuse andrecycling as primary solid wastemanagement methods.

Every marina facility shouldbe aware of what items they arediscarding and how they are disposing ofthem. The best way to do this is to develop asolid waste management disposal plan foryour shop. The first step in developing yourplan is to conduct a waste audit of yourbusiness. A waste audit will show where youcan improve your purchasing practices andhelp identify potential waste reduction andrecycling options. Also, a waste audit willhelp you get accurate information on thenature and quantity of your waste. Businessesthat implement waste reduction, reuse andrecycling have benefitted by reducing costs.

Here are some waste reduction andrecycling strategies your business can adopt:# Use reusable shipping containers and

pallets.# Purchase reusable products and supplies.# Recycle your office paper, plastics, glass,

metal and other materials.# Make sure your employees practice

waste reduction and recycling methods.# Purchase products with recycled content.# Turn off computers, lights, and other

electrical equipment when you leave forthe day, or turn them off when not usingthem.

# Place trash receptacles in convenientlocations for marina patrons, and at boatlaunch sites.

# Utilize 2-sided copying wheneverpossible, and use waste paper as scrap ordraft paper.

# Use e-mail and automated formswhenever possible.

# Consolidate files and functions in orderto reduce duplication.

# Use paper and other materials withrecycled content.

# Encourage the use of coffee mugs andreal spoons versus styrofoam and plastic.

# When purchasing print jobs, specifyenvironmentally friendly options such asrecycled paper, no extra packaging, andsoy-based inks.

# Consider the total costs of energy,supplies, and waste pick-up and assignresponsibility for waste reduction to theproper staff.

# Send copier and printer toner cartridgesback to the supplier for refurbishing.

# Purchase products with less packaging.# Purchase products made from recycled or

post-consumer materials.# Purchase only as much of a chemical as

you can use and follow all labelinstructions.

# Try to find alternative products withouthazardous contents that will accomplishthe same task.

# By in bulk, when practical, but do not bymore than you can use before the productexpires.

# Take batteries to recycling facilities.# Mulch or compost your yard waste and

vegetable scraps from your cafeteria.# If necessary, caulk windows and doors

and install storm windows, doors, andinsulation to conserve energy.

# Use energy-efficient bulbs and fixturesand install light sensors in rooms.

# Use baking soda as a cleaner instead ofmore toxic solutions.

# When painting, use latex paints wheneverpossible.

# When using paint thinner for cleanup,save the used thinner is a covered bucket;the paint solids will settle to the bottom,


and the thinner can be poured off andreused.

# Conserve energy by using energy-efficient heating and air conditioningsystems that use solar power or naturalgas.

# Install low-flow water faucets and lowcapacity toilets.

# Eliminate all leaks and take measures tominimize the potential for spills.

# Use non-toxic and recycled materialswhenever possible.

# Improve the operating efficiency ofequipment.

# Improve material receiving, storage, andhandling practices and policies to reducewasted product.

# Conduct a review of the use of rawmaterials and generation of wastes andconsider the full cost of wasting.

# Recycle whatever wastes cannot beavoided.

#In addition, you may want to identify the

materials that comprise the largest portion ofyour waste stream and establish a separaterecycling program targeting the materialsidentified.

To obtain a copy of the Waste AuditReference Manual, call the DEC Bureau ofWaste Reduction and Recycling at (518) 402-8705.


If your facility utilizes solvents,corrosives, degreasers, petroleum products,etc., you may have to comply with State andfederal bulk storage regulations. These bulkstorage regulations pertain to tankregistration, upgrades, and inspections for thesafe handling of petroleum products, and thestorage of over 1,000 different hazardoussubstances as well as stringent designstandards for new construction.

The bulk storage regulations consist ofpetroleum bulk storage and chemical bulkstorage regulations. The storage of hazardoussubstances are regulated under the ChemicalBulk Storage (CBS) program. Both programsare outlined below.

STORAGE REQUIREMENTSFOR USED OIL

Any tank storing used oil, no matter whatthe size, is subject to petroleum bulk storagerequirements, including registration withDEC. Drums do not have to be registered.There are two product categories, i.e., used oil(collection for reprocessing or disposal offsite), and use oil fuel which is burned onsite toprovide heat. You can obtain a copy of theregistration form from our website at:http://www.dec.state.ny.us/website/der/bulkstor/forms/index.html

HAZARDOUS SUBSTANCESNew York’s chemical bulk storage (CBS)

program regulates facilities with undergroundstorage tanks (USTs) of any capacity andaboveground storage tanks (ASTs) of 185gallons or greater capacity. To be regulatedunder the CBS program, tank must store ahazardous substance on the list of hazardoussubstances in Part 597 of the regulations. Thesubstance must be present in concentrations of

one (1) % or more by weight or volume eithersingly or in combination. The CBSregulations are found in 6 NYCRR Part 612-614. All part of these regulations becamefully effective in 1994. The CBS regulationsestablish requirements for facility registrationand spill reporting as well as requirements fordesign, construction, installation, operation,maintenance, repair, monitoring, testing, andinspection of storage facilities. Theregistration requirements and fee schedulesare found in Part 596.

Storage Requirementsfor Used Antifreeze

If you are accumulating used antifreeze(ethylene glycol) and temporarily storing it ina stationary tank, the tank may be subject tothe CBS regulations. The collection tank issubject to the CBS regulations if both of thefollowing conditions are met: 1) The tank isunderground of any capacity, or 185 gallonsor greater aboveground; 2) The product is nota RCRA hazardous waste*, will not berecycled, but will be sent off site for disposalas a solid waste.

* To determine if used ethylene glycol is aRCRA hazardous waste, the product wouldhave to be tested to determine whetherthreshold concentrations of certain heavymetals or organic chemicals are exceeded. Ifthese threshold concentrations are exceed, theused ethylene glycol becomes a RCRAhazardous waste and is exempt under the CBSprogram.

Bulk Storage Regulations

http://www.dec.state.ny.us/website/der/bulkstor/forms/index.html


Regulatory Deadlines andRequirements for Facility Upgrade

Part 598 establishes the upgrade requirementsfor USTs with a deadline of December 22,1998 (the same as EPA’s UST program) andfor ASTs with a deadline of December 22,1999. Facilities constructed after February11, 1995 must meet the standards for all newor substantially modified facilities (Part 599).Substantial facility modification occurs whena tank is added or permanently closed or anexisting tank is replaced. Repairs andreplacements to ancillary piping, vents,gauges, pumps, etc., are not consideredsubstantial modifications.

New and replacement USTs must havecorrosion resistant tanks and piping systems,secondary containment, a leak monitoringsystem, spill and over fill prevention devices,and have the required valves, gauges andalarms.The deadline for upgrading ASTs wasDecember 22, 1999. After that date, steeltanks in contact with soil must be cathodicallyprotected. Also, tanks constructed of materialswhich could melt when exposed to fire mustbe protected from fire. All ASTs must havesecondary containment and be equipped witha product level gauge and an overfillprotection device. Storage tanks must beequipped with valves to control the flow ofproduct for each tank connection.

Secondary Containmentat Transfer Stations

A transfer station is an area where pipes orhoses are connected and disconnected toempty or fill a storage tank. This includesrailways, roads, containment basins, curbs,collection sumps, and impervious pads wherea vehicle or container is located to off-load orto receive a hazardous substance, where acoupling to a transfer line is made for thepurpose of hazardous substance transfer, or

where a system to collect and contain spillsresulting from transfer is located. As ofDecember 22, 1999, all transfers of hazardoussubstances at a registered facility must occurwithin a transfer station equipped withpermanently installed secondary containment.The goal of the program is to control anyrelease from bulk storage systems and transferoperations and to reduce or eliminate releasesto soil, surface water, and groundwater.

Spill Prevention Report (SPR)The SPR is one of the cornerstones of theCBS regulations and every CBS facility wasrequired to have one by August 11, 1996. Themajor elements of the SPR require a listing ofall spills over the previous five-year period, anassessment of the causes of those spills, acompliance assessment of bulk storageoperations, records of inspections, a spillresponse plan, and management’s signatureindicating acceptance and approval of thereport. A proper SPR can minimize andeliminate injury, loss of life, hospitalization,subsequent remediation, and reduce overallliability.

PETROLEUM PRODUCTSThe Petroleum Bulk Storage (PBS)

regulations became effective on December 22,1985. The regulations apply to UndergroundStorage Tanks (USTs) and AbovegroundStorage Tanks (ASTs) at PBS facilities with acombined storage capacity of over 1,100gallons.

The PBS regulations are contained in 6NYCRR 612-614. Under these regulations,owners were required to register existingfacilities with DEC by December 27, 1986.Facilities must re-register every five years.Registration fees vary from $50 to $250 perfacility, depending on combined storagecapacity of the facility. New facilities must beregistered before being placed into service.DEC must be notified within 30 days prior to


substantial facility modification (adding,permanently closing or replacing a tank).

Nassau, Suffolk, Rockland, Westchester,and Cortland Counties administer the programin these localities, pursuant a delegationagreement with DEC. Because these countiesmay have more stringent requirements thanthose of the State, owners and operatorsshould contact the county to learn of specificlocal requirements.

All facilities regulated under PBSprogram must meet certain storage andhanding requirements established by DEC.These include color coding of fill ports, spilland over fill prevention devices, andsecondary containment for abovegroundtanks. Aboveground tanks must be inspectedmonthly visually and operators of USTs mustkeep, reconcile and maintain daily inventoryrecords. In the event of an unexplainedinventory loss, DEC and the tank owner mustbe notified within 48 hours. Substandard tanksand piping systems must be tested every fiveyears and leak detection devices must bemonitored weekly. Ten-year structuralinspections are required ASTs which are10,000 or more in capacity and rest directlyon the ground.

Tanks that are temporarily out-of-service(30 days or more) must be drained of productto the lowest draw off point. Fill lines andgauge openings must be capped or plugged.Inspection and registration must continue.Tanks which are permanently out-of-servicemust be emptied of liquid, sludge andrendered vapor free and must either beremoved or filled with solid inert material,such as sand or concrete slurry. DEC must benotified within 30 days of filling or removal.

Part 614 applies to all new andsubstantially modified facilities. New USTsmust corrosion resistant and have secondarycontainment. Although there are severaloptions for secondary containment listed inthe regulations, a double-walled tank with

monitoring in the interstitial space is is themost effective and is recommended. Althoughinterstitial space monitoring must be usedwith a double-walled tank, other leakdetection options which may be used includean automatic tank gauging (ATG) system, orone or more observation wells are availablewithin secondary containment. New ASTsmust be constructed of steel. If their bottomrests on the ground, the tank must havecathodic protection. An impermeable barriermust be installed under the tank bottom, withmonitoring between the barrier and the tankbottom. New underground piping systemsmust be corrosion resistant and designed witha 30-year life expectancy. Piping systemsmust be constructed of fiberglass-reinforcedplastic or other non-corrodible materials.

Secondary ContainmentSecondary containment defines any structurethat is designed to prevent leaks and spillsfrom reaching the land or water outside thecontainment area. All aboveground tanks witha capacity of 10,000 gallons or more must beequipped with secondary containment. Allaboveground tanks smaller than 10,000gallons are required to be equipped withsecondary containment if the facility is withinclose proximity to ground or surface waters ofthe state. Facilities within 500 feet of thefollowing resources may be considered inclose proximity to ground or surface waters:

# perennial or intermittent stream;# public or private well;# primary or principal aquifer;# wetlands as defined in 6 NYCRR 664;# lake, pond, estuary, etc.; or# storm drain.

FEDERAL UST REGULATIONSIf you store motor fuels, used oil, or

lubricating oil in USTs that are over 110gallons in capacity, these storage systems my


be subject to the federal Underground StorageTank (UST) regulations (40 CFR 280). Theseregulations are similar to the State PBSregulations, but exceed requirements of theState regulations in several areas. Theseinclude the December 22, 1998 deadline forupgrading, replacing or permanently closingan UST system. Upgraded systems arerequired to have corrosion resistant tanks andpiping, leak detection, and spill and overfillprevention devices.

When an UST system is permanentlyclosed, a site assessment must be preformed tocheck for contamination. DEC guidance forperforming a site assessment is found inSPOTS #14. For more information on thefederal UST program, go to EPA’s web site:www.epa.gov/OUST, or call the RCRA/SuperFund Hotline at 1-800-424-9346.

WHEN TO REPORT A SPILL?Reporting spills is a crucial first step in

the response process. There may be severaldifferent state, local, and federal laws andregulations that require spillers to reportpetroleum and hazardous materials spills.

Hazardous SubstancesAssociated with each regulated hazardoussubstance under Part 597 is a ReportableQuantity (RQ); one for a release to air and onefor a release to land or water. Appropriateparties are required to take prompt remedialaction to protect human health and theenvironment in the event of a spill. A spill thatexceeds the RQ but is contained by effectivesecondary containment, and which is cleanedup within 24 hours, is not reportable unless itcould result in a fire or explosion or pose ahealth risk to adjacent parties. When a spillcannot be contained, it is considered a releaseto the environment. When a release exceedsthe RQ for that substance, the facility mustreport the release to the DEC Spill Hotline

(800) 457-7362 within two hours ofdiscovery. Part 595 applies to all releases,including those from chemical process tanks,chemical fires, explosions, and non-registeredfacilities.

Petroleum ProductsPetroleum spills must be reported to DECunless they meet all of the following criteria:• The spill is known to be < 5 gallons.• The spill is contained and under the

control of the spiller.• The spill has not and will not reach the

State’s water or any land.• The spill is cleaned up within two hours

of discovery.

All reportable spills must be reported to theDEC spills Hotline at 1-800-457-7362.

http://www.epa.gov/OUST


WHAT ARE PESTICIDES?A pesticide is any substance or mixture of

substances intended for preventing,destroying, repelling, or mitigating anyinsects, rodents, fungi, weeds, or other formsof plant or animal life or viruses. Marinas mayrequire the use of pesticides to control avariety of plant or insect pests in and aroundtheir facility, but the most visible use ofpesticides may be the application ofantifouling paints to boat bottoms or marinestructures to control aquatic organisms, suchas barnacles and algae. These products, whichmay contain compounds with tin or copper,are toxic to the aquatic environment and mustbe used carefully. The New York Stateregulations pertaining to these and otherpesticides are found under 6 NYCRR Parts320-329. For more specific informationregarding the use of pesticides, please call theBureau of Pesticides Management at (518)402-8781.

P E S T I C I D E P R O D U C TREGISTRATION

The Environmental Conservation Law(ECL) §33-0701 requires every pesticideproduct which is used, distributed, sold oroffered for sale in New York State to beregistered with DEC. Pesticides are registeredas either general-use pesticides (orunclassified), which may be sold by anyoneor used by anyone on their own property, orrestricted-use pesticides, which may be sold,distributed, purchased, possessed and usedonly by the holder of a written permit and/orpesticide applicator certification issued byDEC. Pesticides classified as restricted-usemay pose a significant risk to the applicator,the public health or the environment if stored,

handled or applied improperly. A commercialpermit, issued by DEC, is required to sell,offer for sale, or possess for the purpose ofresale any restricted-use pesticide.

Businesses may check if the productsthey use are registered in NYS or if they areclassified as general or restricted-use by goingto the Cornell Pesticide ManagementEducation Program (PMEP) website atpmep.cce.cornell.edu/plms ,or you can go tot h e D E C w e b s i t e a twww.dec.state.ny.us/website/dshm/pesticid/pestreg.htm.

P E S T I C I D E A P P L I C A T O RCERTIFICATION AND BUSINESSREGISTRATION

The pesticide applicator requirements areexplained in detail in Title 6 of the OfficialCompilation of Codes, Rules and Regulationsof the State of New York (6 NYCRR) Part325, Application of Pesticides.

Marina owners, or their employees, whoapply antifouling paints, as a service to boatowners, must register annually as a businesswith DEC and must employ at least onecommercial pesticide applicator, fullycertified in subcategory 5D - AquaticAntifouling Paints. This certified applicatormay directly supervise pesticide apprenticesor technicians, employed by the marina, whoapply antifouling paints. An apprentice isrequired to receive training and applicationexperience, according to 6 NYCRR Part325.10 before the apprentice can applyunclassified antifouling paints under theoff-site direct supervision of a certifiedapplicator.

Pesticides Management Regulations

http://pmep.cce.cornell.edu/

http://www.dec.state.ny.us/website/dshm/pesticid/pestreg.htm


BOAT OWNERSThe application of unclassified

antifouling paints by boat owners, on marinaproperty, is prohibited unless the boat ownerpersonally owns the drydocked boat beingpainted and leases a specific area, from themarina owner, to do such work. These boatpainting areas must be located away from thewater's edge and designed to prevent runoff.DEC recommends that marina owners monitorsuch applications to assure that paint chips orother wastes are collected and prevented fromcontaminating the surrounding area. Inaddition, DEC recommends that leaseagreements state that boat painters mustfollow label directions and to notify themarina owner immediately if a spill occurs.

Applications made by boat owners in thismanner occur on marina property so anycontamination or other environmentalproblems resulting from the customerapplying antifouling paints are still theresponsibility of the marina owner. Followingthese recommendations will greatly reducepotential liabilities related to these activities.

PESTICIDE USE SAFETY ANDPERSONAL PROTECTION

Pesticides must be used in such a mannerand under such wind and other conditions asto prevent contamination of people, pets, fish,wildlife, crops, property, structures, lands,pasturage or waters adjacent to the area ofuse. Pesticides must always be used only inaccordance with label and labeling directions.

Prior to any pesticide application, thecertified pesticide applicator must providesafety training to individuals using pesticidesunder the certified pesticide applicator's directsupervision. The training shall include, but isnot limited to, the following topics:site-typical detailed guidance for pesticideuse, pesticide safety, and the use of personalprotective equipment including selection of

appropriate respirators.Certified pesticide applicators must

provide relevant safety information, restrictedentry intervals and personal protectiveequipment and other safety equipment beyondnormal work attire, as specified by thepesticide label, to individuals using pesticidesunder the certified pesticide applicator's directsupervision. However, if the certifiedpesticide applicator is not the owner ormanager of a registered pesticide business, theowner or manager of the marina must providesuch information and equipment.

All equipment containing pesticides anddrawing water from any water source shallhave an effective anti-siphon device toprevent backflow. Empty noncombustiblepesticide containers, such as plastic or metalcontainers, must be cleansed before disposal,using the three-rinse technique as defined in 6NYCRR 325.1, or other methods approved bythe Department, except that containers ofready-to-use pesticides that do not requiredilution must be drained only for one 30-second period.

AQUATICS PERMITS Section 15-0313 of the ECL providesNYSDEC with the authority to require anaquatic permit for the application of pesticidesto water bodies of New York State that aregreater than one acre in size or with an outletto surface waters. These standards are furtherdefined in regulation, specifically 6 NYCRRParts 327, 328 and 329, which list specificrequirements for the control of aquaticvegetation, undesirable fish and aquaticinsects, respectively.

In addition, aquatic pesticides are alsoregulated under Part 326 which, since April 1,1993, has classified all aquatic pesticides asrestricted. This means they can only bepurchased and used by individuals who either


possess pesticide applicator certification, orpossess a special permit for the purchase anduse of a restricted pesticide. An aquatic permitor a special permit for the purchase and use ofa restricted pesticide may be obtained fromthe Department's Regional Office that coversyour area. I N T E G R A T E D P E S TMANAGEMENT

In an effort to reduce to the greatestextent possible the use of chemical pesticides,your facility should institute an integrated pestmanagement plan (IPM). An IPM plan is asystematic approach to managing pests,including but not limited to identifying neededrepairs and keeping storage areas within thefacility clean. The plan should focus on long-term prevention or suppression of pestpopulations with minimal impact on humanhealth, the environment, and non-targetorganisms. IPM incorporates all reasonablemeasures to prevent pest problems byproperly identifying pests, monitoringpopulation dynamics, and utilizing cultural,physical, biological or chemical pestpopulation control methods to reduce pests toacceptable levels.

PESTICIDE REPORTING LAWAND RECORD KEEPING

The Pesticide Reporting Law (PRL)requires the annual submission of reports, byFebruary 1 of each year, detailing pesticidesales and use activities. All commercialapplicators shall maintain pesticide userecords for each pesticide applicationcontaining the following:

a. EPA registration number;b. product name;c. quantity of each pesticide used;d. date applied;e. location of application by address(including five-digit zip code).

Such records shall be maintained for aperiod of not less than three years. Allcommercial applicators shall also maintaincorresponding records of the dosage rates,methods of application and target organismsfor each pesticide application. These recordsshall be maintained on an annual basis andretained for a period of not less than threeyears and shall be available for inspectionupon request by the department. For moreinformation you may e-mail DEC [email protected], or call toll-free at1-888-457-0110.


Absorbents and Floor Dry

Waste Stream ManagementTo assist the marina industry in complying with environmental regulations, this section discussessome best management practices for waste streams typically generated by this industry. The list ofwaste streams that follows includes an interpretation of the DEC regulatory requirement and thepreferred waste management techniques.

REGULATORY REQUIREMENTSIf your facility uses alkaline or acidic

cleaning solutions, you must make ahazardous waste determination on the spentsolution before disposing of it. If the pH ofthis waste is 2.0 or less; or 12.5 or greater,prior to any waste treatment, then these arehazardous wastes. In addition, these wastescould be hazardous if they fail the TCLP testfor metals.


Chemical substitution is one of the bestways to reduce your hazardous wastegeneration during your cleaning process.Another tip is to use mild alkaline and acidiccleaners. Mild alkaline detergent solutions,such as sodium hydroxide, sodium carbonate,sodium phosphate, and borax, are used toclean many substrates because no hydrogengas is formed during the process. Thesecleaners also remove rust, scale, and oxidesfrom metal surfaces. Generally, the strongerthe solution, the faster it cleans. However,mild solutions are used in the process line forthorough rinsing.

For more information on abrasive and alkalinecleaning compounds, refer to the partscleaning and degreasing information.

REGULATORY REQUIREMENTSYou must make a hazardous waste

determination on all absorbent pads or floordry material that is used to clean up spills. Ifyour facility has a spill that could be harmfulto public health or the environment, you mustcontact DEC immediately at 1-800-457-7362.

AlertBefore you discharge absorbents or floor dry

into dumpsters, make sure you comply with

all the necessary DEC regulations.


Good housekeeping practices are the bestway to minimize spills. The fewer spills thatoccur, the less absorbents, floor dry or otherabsorbent material will be needed to clean upthese spills. Here are some tips to help youprevent spills at your facility:# Train your employees. Since employees

are the first line defense against spills,make sure that each employee is taughtthe importance of spill prevention.

# If you must use absorbents, make sure topurchase absorbent material that can bereused. Absorbent “socks,” for example,can be used about 10 times.

# Make sure all of your tanks or drums thatcontain liquids have some kind of

Abrasive and AlkalineCleaning Compounds


Burn Barrels and OpenBurning

Coating Operations

containment in case of a leak or spill.# After wiping up a spill with absorbents or

a mop, drain excess liquids into the wastecontainer for that particular waste. Forexample, if you are cleaning up an oilspill, squeeze the excess oil in thecontainer marked USED OIL.

# Use shop towels to wipe up small spills,then send your shop towels to belaundered.

# Consider an award program foremployees that keep their work areasclean or for workers who come up withgood pollution prevention ideas.

REGULATORY REQUIREMENTSBurn barrels and all other types of open

fires are specifically prohibited by NYSDECair regulations under 6 NYCRR Part 215.New York State law prohibits the burning fordisposal of rubbish generated on site bycommercial activities. Burning solid wastegenerated by your business would constituteviolations of both air regulations and solidwaste regulations.

REGULATORY REQUIREMENTSIf your marina performs any painting or

coating operations, a hazardous wastedetermination must be made on waste paint,solvents/thinners, paint sludge, primer waste,and spray booth filters. The paints and paintsludges may be hazardous if they containheavy metals, such as arsenic, lead andchromium. The solvents may be

characteristically hazardous due to theirignitability or they could be a listed hazardouswaste. Also, many primers, lacquers, andenamels are flammable.

During metal coating operations, volatileorganic compounds (VOCs) and hazardous airpollutants (HAPs) are released into theenvironment. These pollutants are regulatedunder the Clean Air Act. To learn more aboutthese requirements, refer to the section on airregulations.


Here are some tips on minimizing thewaste from coating operations:# Train employees in paint application

techniques. Proper training in correctlyapplying paint can reduce your waste andVOC emissions.

# Make sure your facility uses high-volume/low-pressure (HVLP) sprayguns. These spray guns have transferefficiencies of about 60 to 80 percentcompared to standard spray guns withless than 50% efficiency.

# Train employees in the proper cleaningand maintenance of equipment. This isessential for achieving a high qualityfinish, especially in the new spray guns.

# Perform all spray painting in an enclosedspray booth equipped with filters.

# When cleaning spray guns with solvents,use smaller diameter tubing so that youwill use less solvent.

# The solvent used to clean spray guns canbe reused to thin paint of the same color.

# If possible, switch to water-based paintsand primers.

# Switch from lacquer to enamel-basedpaints. Lacquer paints may contain 70 to90 percent solvent by volume, whileenamels contain 55 to 75 percent solventby volume.


Floor Drains and Wastewater

# Use solvents with low or no VOCcontent.

# Purchase a small solvent distillation unitto recycle your paint thinners andsolvents.

The wastewater discussed in this sectionrefers to all the wastewater generated at yourfacility that is not treated before it isdischarged. This can include wastewater fromspills, clean-up, leaks, or any other industrialwastewater that does not get treated.

Regulatory AlertDo not discharge wastewater to your floor

drains unless they are connected to either a

public sewer or a holding tank.

Wastewater from marinas may containheavy metals, toxics, solvents, oil and grease,gasoline, and other materials that could behazardous. Care should be taken not todischarge these items, or other contaminantsinto floor drains unless you have approvalfrom your local wastewater treatment facility,or are permitted by DEC.

REGULATORY REQUIREMENTSThe Environmental Conservation Law

prohibits the discharge of pollutants intosurface or groundwaters without a StatePollutant Discharge Elimination System(SPDES) Permit. The Safe Drinking WaterAct, under the Underground Injection Controlprogram administered by EPA was designedto prevent contamination of groundwaterresulting from the operation of injection wells.In addition, the disposal of hazardous waste

into floor drains may be a violation of thefederal Resource Conservation and RecoveryAct (RCRA).

If you have floor drains at your facility,you must do one of the following:

# Make sure they are connected to a publicsewer system. In most cases, floor drainsare connected to a publicly ownedtreatment works (POTW). However, theowner should refer to the Local CodesEnforcement Officer and the Sewer UseOrdinance before making any newconnections. Some municipalities restrictfloor drains from being connected to thesewer system, depending on the type ofoperation. Also, you may be required byyour POTW to connect an oil/waterseparator between the floor drains andthe sewer system. Oil/water separatorsshould be checked on a regular basis tomake sure they are working properly.This includes cleaning out the sludgeannually, testing it for toxicity and thendisposing of it properly. If you are aconditionally exempt small quantitygenerator (CESQG), you can transportthis sludge to an approved facility. Thisincludes transporting dried sludge to yourlocal landfill, but prior approval isneeded. See the resource guide sectionfor locations of the household hazardouswaste collection facilities.

# If no POTW is located in your area, makesure your floor drains are connected tosome kind of holding tank, where thewastewater can be pumped out andtreated or disposed of properly. All

wastewater should be hauled away by a 6 NYCRR Part 364 DEC permitted waste transporter to avoid any liability.


Fluorescent Bulbs and OtherHazardous Lamps


Wastewater can be generated at yourfacility from washing floors or other cleaningoperations. By minimizing the amount ofwastewater, you reduce the amount ofwastewater and sludge that must be managedor discharged. Here are some tips to help youminimize your generation of wastewater:

# Use dry floor cleaning methods. Thisincludes sweeping and vacuuming.

# Train employees to use water efficiently.# Use only nontoxic soaps to clean floors

and marina craft.# Prevent drips and spills from reaching the

floor.# If a small spill does occur, clean it

immediately with shop towels or mops.This was discussed in the shop towelsection. Never clean spills by hosingthem down with water.

# Maintain marina craft only in areaswhere there are no floor drains. If floordrains are present, seal them off duringwork to prevent spills from entering thedrains.

# Never have floor drains where hazardousmaterials are stored.

# If you collect your wastewater in aholding tank, try to reuse it wheneverpossible.

# Consider buying a water recycling unitto treat your wastewater on site.

# If your wastewater is nonhazardous,purchase equipment to evaporate yourwastewater. Note that evaporators mayrequire an air permit or registration.Evaporator bottoms may be hazardouswaste.

# Wash your marina craft at an off-sitecommercial car wash.

# If you service vehicles at your facility,brush snow and ice off before bringingthem into the service shop.

REGULATORY REQUIREMENTSCurrently, most waste fluorescent bulbs

(referred to hereafter as "fluorescent lamps")are hazardous wastes due to their mercurycontent. Other examples of lamps that, whenspent, are commonly classified as hazardouswaste include high-intensity discharge (HID),neon, mercury vapor, high pressure sodiumand metal halide lamps. The U.S.Environmental Protection Agency (USEPA)added hazardous waste lamps to the UniversalWaste Rule (64 FR 36465 - 36490) in 1999,and DEC adopted these regulations on March15, 2002. Handlers of hazardous waste lampsare able to choose between handling theirlamps under the traditional regulatory schemeor as universal wastes. However, once youdeclare your lamps universal wastes, you mustcontinue to handle them as universal wastes.Jumping back and forth between thetraditional RCRA approach and the UniversalWaste Rule in order to avoid anyrequirements is prohibited. If a handler ofhazardous waste lamps fails to comply withthe Universal Waste standards, they may beconsidered to be in violation of existinghazardous waste laws and regulations.

Most marinas are considered SmallQuantity Handlers of Universal Waste definedas handlers of less than 5,000 kg or 11,000lbs. of total universal wastes (hazardousbatteries, certain hazardous pesticides,hazardous thermostats, or hazardous lamps,calculated collectively) on site at any time.


Fuel Filters

Gasoline

Lead Acid Batteries

The requirements for Small Quantity Handlersof Universal Waste (including fluorescentlamps) require that lamps be packaged in away to minimize breakage, that any brokenlamps are immediately cleaned up, and thatcontainers are properly labeled.

More information on handling offluorescent lamps and universal wastes can befound on the DEC web site at:www.dec.state.ny.us/website/dshm/hzwstman/bulbs2.htm.You can also contact the WasteManagement Section of the Division of Solidand Hazardous Materials at (518) 402-8633.

REGULATORY REQUIREMENTSMetal fuel filters that are drained of all

free liquids and taken to scrap metal yards forrecycling are exempt from hazardous wasteregulations. Otherwise, fuel filters must bemanaged as hazardous waste due to theignitability characteristic of the gasoline. Fuelfilters cannot be discarded in dumpsters or inthe trash even when properly drained, sincethey may contain benzene or lead which ismay be considered hazardous when a TCLPtest is performed.

REGULATORY REQUIREMENTWaste gasoline is regulated as a

hazardous waste if it is sent for disposal. Formore information on the hazardous wasteregulations, please request a copy of themanual Environmental Compliance andPollution Prevention Guide for Small

Quantity Generators by calling (800) 462-6553 or from the DEC web site at:http://www.dec.state.ny.us/website/ppu/p2pub.html.

Waste gasoline is not considered ahazardous waste if it is recycled or burned asa fuel. Waste gasoline should be stored inproperly grounded, labeled and closedcontainers on an impermeable surface withspill controls.

REGULATORY REQUIREMENTSIf your lead-acid batteries are recycled,

they do not have to be counted as hazardouswaste, but are still subject to limitedhazardous waste regulations, such as storagerequirements. Lead acid batteries should beproperly stored off the ground and shouldhave proper containment in case of leaks.These batteries should be covered if storedoutside to prevent the corrosive battery acid(which is usually hazardous) from beingwashed in the ground during rain or snowstorms.

If your lead acid batteries are notrecycled, they must managed under thetraditional regulatory scheme as non-exempthazardous waste.


Follow these tips for good managementof lead acid batteries:

S Use an authorized recycler.S Indoor storage is recommended for lead-

acid batteries.S Store batteries on an acid-resistant rack

or tub.

http://www.dec.state.ny.us/website/ppu/


S Batteries stored outside should be storedon impermeable surfaces and should havesecondary containment. Also, it isrecommended that batteries be covered toprevent acid run off.

S Keep a neutralizing agent, such as bakingsoda nearby in case of leaks or spills. If aspill does occur, the waste must betreated as a hazardous waste.

S When stacking batteries, make sure theyare stored so that any fluid from leakingbatteries will not be released to theenvironment.

S Electrolyte fluid in spent batteriescontains a sufficient quantity of lead tomake it a hazardous waste. This fluid, ifdischarged onto the ground, willfrequently make the soil which absorbs ita hazardous waste.

REGULATORY REQUIREMENTSDue to the metals contained in many of

the paints used for the painting of boats andother water vessels, a hazardous wastedetermination should be made before youdecide to discard paint scrapings as a solidwaste. (See commonly asked questions, page65). Paint scrapings should not be disposed ofin a dumpster unless a proper hazardous wastedetermination has been made showing them tobe nonhazardous waste. If chemical paintstrippers are used, such as methylene chloride,you should be aware that the scrapings willbecome hazardous due to the listed wasteintroduced into the paint chips.

Abrasive blasting is often preferred tochemical stripping for removing paints. Thisprocess does not eliminate wastes since themost commonly used blasting media is sand

or grit with a large volume of water. Blastwaste water can constitute the largest singlewaste stream from many boat repair yards.The different types of abrasive blastinginclude: plastic media blasting, water jetstripping, thermal stripping, dry ice pellets,laser paint stripping, and cryogenic stripping.

REGULATORY REQUIREMENTSSpent solvents are dangerous to workers

because they are toxic and emit harmfulvapors. If your facility still uses a partswashing system that contains a hazardoussolvent, you may be generating wastes thathave EPA Hazardous Waste Codes F001-F005. Also, many solvents may be hazardousbecause of ignitability, which have an EPAHazardous Waste Code of D001.

When using hazardous solvents in yourparts washing system, you are required tokeep track of the amount of spent solventgenerated each month and must dispose of thespent solvent as hazardous waste. Thefollowing are some of the common spenthalogenated and nonhalogenated solventsused in degreasing operations which areconsidered hazardous:

*Tetrachloroethylene (Perchloroethylene)Methyl isobutyl ketone (MIBK)Methyl ethyl ketone (MEK)Chlorinated fluorocarbonsTrichlorofluoromethaneCarbon tetrachlorideOrtho-dichlorobenzene*Methylene chloride1,1,1-trichloroethaneMethanol

Paint Scrapings andAbrasive Blast Wastes

Parts Cleaning andDegreasing


IsobutanolTolueneAcetoneXyleneBenzene

*Methylene chloride and perchloroethyleneare not VOCs and they have strict emissionstandards because of their toxic emissions.

If your facility uses any of the aboveparts washing solvents or degreasers, or anyother hazardous solvent not listed above, youshould make every effort to look for a reliablesubstitute that is nonhazardous or lesshazardous. If you do choose to use ahazardous solvent, you must following thehazardous waste regulations.

TYPES OF PARTS WASHERSThere are many opportunities available to

minimize or eliminate your generation ofhazardous solvents. One of your first choicesshould be to use a nonhazardous or lesshazardous parts cleaning system. Here aresome tips you should follow beforepurchasing or leasing your parts washer:

# Buy a parts washer with a lid rather thanan open bucket or pan. This reducesevaporation and spillage of solvent.

# Instead of leasing, purchase your ownparts washer. Service agreements tend tochange your solvents more often, whichgenerates more waste. Also, if you are aconditionally exempt small quantitygenerator, you can transport your spentsolvent and sludge to an approvedfacility.

# Talk to other facilities to find out whichsystem works best. This will save youtime and money trying to decide whichsystem is best for you.

# When a supplier or vendor demonstratesa parts washer, make sure you specifythat he take away the whole unit,including any still-useable solvent, if youdecide not to buy it.

# Buy a parts washer with a drain shelf thatfits inside the basin. This allows solventto drain from parts prior to removingthem from the washer.

# Buy a parts washer with a filtering unitthat will extend the life of the solvent byfiltering out contaminants. Remember,when discarding the filters, a hazardouswaste determination must be made priorto disposal.

# Parts washers that are heated seem towork better than unheated units.

Marinas can choose from several differentcleaning options including halogenatedsolvents, aqueous cleaners, ultrasoniccleaners, and electrocleaning. The followingis a brief description of some types ofcleaning systems.

Solvent CleanersConsidered one of the best parts cleaners,chlorinated solvent vapor degreasers havestrict air emissions standards because of VOCemissions (see air regulations section). Themain advantage of chlorinated solvents, suchas trichloroethylene, perchloroethylene, ormethylene chloride is their cleaningeffectiveness, especially in vapor degreasers. Handling or disposal of hazardous solvents ismore involved and expensive than othercleaners. Because of these costs, marinas areinvestigating alternative cleaning methods.More than likely, your marina will not beusing a vapor degreaser. If you do choose touse this degreasing process, below is a list ofsome methods to improve the efficiency:


S Install refrigeration coils in addition towater coils. Coils can help reduce vaporsby approximately 40%.

S Cover the degreasing unit wheneverpossible. The best type of cover is amotor-controlled cover that closesautomatically.

S Keep the tip of the spray wand below thevapor level during spraying operations.

S Remove parts from the degreaser slowly.Also, raise and lower the basket of soiledparts gently.

S Rack the parts so that the solvent drainsout of the holes, joints, and crevices.

Aqueous CleanersAqueous cleaning refers to the use of water,detergents, acids, and alkaline compoundsrather than organic solvents. These cleanersare also made up of builders, surfactants,inhibitors, and chelators.

Builders are a basic ingredient of aqueouscleaners. The most common builders aresodium hydroxide, potassium hydroxide, andsodium silicates. These are all alkalines andare difficult to rinse.

Surfactants, also known as wetting agents,are used to reduce the surface tension of thecleaning solution. Emulsifiers take oils intothe solution and keep them from re-contaminating the workpiece. Unfortunately,most surfactants are also emulsifiers. Aqueouscleaners work by breaking down the organicsoils with builders and solubilizing them withemulsifiers. This tends to leave a large amountof spent wastewater. Weak emulsifiers,however, tend to keep the oils in suspensionas long as the solution is agitated, but theemulsion breaks when the agitation stops. Thesoils can be removed and the solution can bereused.

Inhibitors reduce the effect of highlyalkaline or acidic cleaners on sensitivesubstrates. Inhibitors prevent rusting oroxidation of parts after cleaning. Chromatesand silicates are common pH inhibitors, butchromates have environmental disadvantages.Also, inhibitors can make rinsing moredifficult and adversely affect subsequentplating operations.

Chelating agents are designed to keep themetal ions in solution. This, however, cancause problems with wastewater treatment.

Aqueous cleaners are among the most popularfor degreasing parts and offer a goodalternative to petroleum-based andhalogenated solvents. The most commonaqueous processes are: immersion withultrasonic agitation, immersion withmechanical agitation, or spray washing.Aqueous cleaners can generally be usedinstead of solvent cleaners to remove soils andparticulate matter. However, when soils andgreases are part of the contamination, othersteps might be needed to provide adequatecleaning. Rinsing and drying are of greatconcern because water can remain on the partsand cause rust. Therefore, aqueous systemsrequire more elaborate rinsing and dryingprocess.

In many cases, wastewater from aqueouscleaners or semi-aqueous processes may needto be treated before discharging to a publiclyowned treatment works (POTW).Contaminants include organic matter (oil andgrease), metals, and alkaline cleaners that mayraise the pH to unacceptable levels.Pretreatment technologies include gravityseparators, ultrafiltration, chemical treatment,precipitation, and carbon adsorption. If yourfacility is treating wastewater from aqueous orsemi-aqueous processes, see “Can You Treat


Or Recycle Your Wastewater?” on page 17.

Some benefits of aqueous cleaners include:

# Less risk of hazardous exposure forworkers and more environmentallyfriendly.

# Not flammable or explosive.# Oils and greases can be removed more

effectively.# Potential savings in disposal costs.

The sludge from oil, grease, dirt and othercontaminants should be cleaned outfrequently. Prior to disposal, you must makea hazardous waste determination on thesludge. Nonhazardous sludge can be hauledby a septic tank company or, if dry, taken to alandfill. If you are a conditionally exemptsmall quantity generator (CESQG), driedsludge that is considered hazardous can betaken to an approved DEC facility as long asyou get prior approval from the facilityoperator. Check with your local landfilloperator for requirements.

Semi-Aqueous CleanersThese cleaners are also called: less-toxicsolvents, less-hazardous solvents, non-halogenated solvents, petroleum-basedsolvents or terpene solvents.

Semi-aqueous cleaners can be dissolved inwater or applied in a concentrated form. Theyare called semi-aqueous because they can beapplied either way. Terpenes arehydrocarbons derived from wood or citrusfruits, usually orange or lemon peel oils. Mostof the semi-aqueous cleaners are not ozonedepleters, but they are highly toxic to aquaticlife, and they may still be a hazardous wastewhen spent. A hazardous waste determinationshould be made prior to disposal.

Ultrasonic CleanersThis method uses high frequency sound wavesto improve the cleaning efficiency of aqueousor semi-aqueous cleaners. The sound wavescreate microscopic sound bubbles thatimplode when the sound wave moves and thezone changes from negative to positivepressure. This process exerts enormouspressure (approximately 10,000 psi) andtemperatures that loosen the contaminants andactually scrub the workpiece. Ultrasoniccleaning allows nonchlorinated degreasing tobe practiced in applications where solventshad formerly been the only effectivedegreasing tool. Ultrasonic cleaning can beused on ceramics, glass, aluminum, andplastic, as well as electronic parts, wire,cables, rods, and detailed items that might bedifficult to clean by other processes.

ElectrocleaningElectrocleaners are basically heavy-dutyalkaline cleaners that are used with an electriccurrent, either reverse, direct, or periodicreverse. These systems are designed for soilremoval and metal activation where the workis immersed in the solution and current isapplied. The objective of electrocleaning is toremove all the soils and activate the metalssurface. The gas scrubbing of the oxygenassists in the removal of soils, while thereverse current aids in soil removal andprevents the deposition of any metallic film ornon-adherent metal particles. A dilute mineralacid dip usually follows the final cleaner toneutralize the alkaline film on the metalsurface.

SOLVENT DISTILLATIONIf hazardous solvents must be used at

your facility, consider purchasing a solventdistillation unit to recycle your solvents. Forexample, if your facility generates five gallons


Shop Towels

of solvent waste, you may be able to reclaimfour and a half gallons of solvent. This wouldleave you with only one half gallon of sludgeto dispose of as hazardous waste. This sludgeis called “still bottoms.” Solvent is reclaimedby heating spent solvent to its boiling point ina “still”, and then cooled, which producesnearly pure liquid solvent that can be reused.Spent solvent need only be counted the firsttime it is generated in a calendar month if it isreclaimed and reused on site. If spent solventsare counted, then still bottoms don’t need tobe counted for the purpose of determininggenerator category, but do need to bemanaged as a hazardous waste. If, however,the solvent is recycled without prior storageor accumulation, then you don’t have tocount that quantity, but you must count thesludge for determining generator category.

B E S T M A N A G E M E N TPRACTICESHere are some pollution prevention tips onmanaging your degreasing operations:

# Wipe off parts with a rag or wire brushbefore soaking in parts washer.

# Do not clean parts unnecessarily.# If possible, try to maintain two parts

washers so that you can use one for pre-rinsing.

# If your parts washer doesn’t have a dripshelf inside the tub, use a drip tray todrain cleaned parts.

# Turn off solvent stream and cover theunit when not in use. If your unit isequipped with a heating element, turn itoff at the end of the day.

# Store solvent waste in closed containers.# Do not fill cleaning machine above fill

line.# Clean up spills immediately.# Store wipe rags in closed metal

containers.# Do not agitate solvent to the point of

splashing.# When cover is open, control room drafts.# Do not clean absorbent materials.# Use aqueous or semi-aqueous cleaning

systems.

Note: CFCs are prohibited for use in solventcleaning machines.

REGULATORY REQUIREMENTSIndustrial rags (also known as shop

towels) or soiled clothing contaminated withlisted or characteristic hazardous wastes donot have to be managed as hazardous wasteswhen they are sent to a commercial ornoncommercial laundry or dry cleaner. Thefollowing conditions must be met:

# There is no exemption for rags or soiledclothing contaminated beyond saturation(containing free liquids). Any rags orsoiled clothing containing free liquids aresubject to full DEC regulation.

# Rags and soiled clothing must bemanaged in accordance with 6 NYCRRPart 372 and Subpart 373-1 until thematerials are sent for laundering andcounted as wastes generated andaccumulated for the purpose ofdetermining generator category. If youare required to submit an annual report toDEC, you must report all rags ashazardous rags in this report.

# All rags and soiled clothing that containflammable materials must be stored andtransported in fireproof containers.


Spray Painting

Used Electronics

B E S T M A N A G E M E N TPRACTICESHere are some tips on managing your shoptowels:

# Send your shop towels to a laundry ordry cleaning service. You only have tomanage your shop towels in accordancewith the hazardous waste regulationsuntil they leave your shop.

# If your facility is large enough, you mayconsider purchasing a centrifuge tocollect and recycle excess solvent fromyour shop towels. Most laundries will notaccept saturated shop towels. Centrifugesmay be costly, which would not makethis a cost-effective purchase for smallbusinesses.

# Store your shop towels in metal safetycans to reduce the risk of fire. If yourshop towels contain solvents, they shouldbe stored in a double-bottom drum toallow the solvent to drip where it can becollected.

See section on air regulations” for regulatoryrequirements.


S All spray painting and abrasive blastingoperations should be performed in spraybooths or tarp enclosures to preventairborne residues from entering the air orsurface waters.

S Eliminate airborne dust particles by using

a dustless sander. These sanders use avacuum collection system connected to aspecial housing on the sander thatcollects the sanding dust.

S Whenever possible, use low VOC paints.S When spray painting indoors, vent fumes

to outside.

REGULATORY REQUIREMENTS

Most discarded electronics that wouldqualify as hazardous waste (e.g., computermonitors) are considered to contain sufficientquantities of scrap metal parts that they can beregarded as scrap metal themselves, and, thus,would be exempted from regulation (scrapmetal exemption) as hazardous waste. Thefollowing conditions must be met:

• Prior Notification [6 NYCRR371.1(c)(7)]: If the generator is not aConditionally Exempt Small QuantityGenerator (CESQG), both the generatorand subsequent handlers in the recyclingprocess in New York State are requiredto submit a "c7" notification to DEC. The“c7" notification gives certain basicinformation, such as the locations ofgenerating and receiving facilities.Although written concurrence from DECis not required, DEC will provide oneupon request (provided the electronicsitem, in fact, qualifies for the exemption).Sample “c7" notification form can befound at www.dec.state.ny.us/website/dshm/hzwstman/c7notifi.pdf

• Scrap metal must ultimately be recycled.The scrap metal exemption requires thatscrap metal pieces actually be reclaimed

http://www.dec.state.ny.us/website/dshm/hzwstman/c7notifi.pdf


Used Oil

RememberAll retention

tanks forstoring usedoil must be

registered withDEC.

from the hazardous electronics and thatthey be recycled.

Note that the scrap metal exemptioncannot apply to a part separated from thewhole component unless that separated partindependently contains scrap metal pieces thatwill ultimately be reclaimed. For example, anall-plastic case that was separated from acomputer monitor could no longer qualify forthe scrap metal exemption, nor could brokencathode ray tube (CRT) glass. Note that anitem which qualifies as hazardous scrap metalis still a hazardous waste if it will be recycled;but it is exempted from regulation.

REGULATORY REQUIREMENTSUsed oil is not regulated as a hazardous

waste if it is recycled or burned for energyrecovery. This means that your used oil, if notmixed or contaminated with hazardous waste,can be managed under the used oilregulations, 6 NYCRR Subparts 360-14 and374-2. Used oil includes used crankcase oil,metal working oils, gear oil, transmissionfluid, brake fluid, hydraulic fluid, dielectricfluid (excluding PCBs), and tank bottomsfrom used oil tanks.

I f y o u a r edisposing of any usedo i l r a t h e r t h a nrecycling or burningfor energy recovery(i.e., spills, soilcontamination, orcleanup), or your usedoil is mixed with otherwastes, then you mustmake a hazardous

waste determination and comply with anyapplicable hazardous waste regulations.

Used Oil StorageUsed oil must be stored in sturdy, leakproofdrums or tanks in compliance with State orlocal building and fire codes, and they mustbe clearly labeled “USED OIL”. In addition,the label for tanks must include the capacityof the tank. Underground tanks must belabeled at the fill port. All used oil tanks,regardless of size, are subject to petroleumbulk storage (Parts 612-614) requirements,including registration with DEC. However,registration fees are required only if thestorage capacity of the used oil tank is greaterthan 1,1000 gallons, and the used oil is burnedon site for heating. Also, petroleum bulkstorage requires more than just registration.See the section in this manual on Bulk Storageregulations for further information.

Accepting Used OilIf your marina’s operations include servicingengines, it may be subject to regulation as aservice establishment. Service establishmentsare entities that have on-premise oil changingfacilities and that sell at least 500 gallons oflubricating oil per year in the course of theirrepair or oil-changing activities. Serviceestablishments must, by law, accept from thepublic at no charge up to 5 gallons of used oilper person per day. Any marina subject toservice establishment requirements must alsopost a sign, in full public view, stating “WEACCEPT USED OIL FOR RECYCLING ATNO CHARGE.” The law also prohibitsservice establishments from charging aseparate fee for used oil recycling on their oilchange customers.

Did You Know?# It takes 42 gallons of crude oil to yield

2.5 quarts of lubricating oil.


Used Oil Filters

# When used oil is recycled, it takes aboutone gallon to yield 2.5 quarts oflubricating oil.

# Used oil from a single oil change cancontaminate a million gallon watersupply for 10,000 people.

# Used oil is the largest single source ofpollution in our nation’s waterways.

# Used oil can contain toxic substances,such as arsenic, benzene, cadmium, lead,and zinc.

# There are 1.2 billion gallons of waste oilgenerated annually in the United States.

Transporting Used OilYour marina must contract with a Part 364permitted waste hauler to pick up your usedoil for recycling or disposal, however, yourmarina can self-transport up to 500 pounds(approximately 55 gallons) of used oil,without a Part 364 permit, but only to:

# A facility that is owned by yourcompany, or,

# A facility permitted by DEC to acceptused oil directly from the generators ofthat oil.


Here are some tips on managing yourused oil:

# Store used oil in tanks or closedcontainers labeled “USED OIL.” This isalso a requirement under the used oilregulations.

# Do not mix hazardous waste with usedoil. This can contaminate your used oilwith hazardous waste, and therefore,prohibit you from managing it as usedoil.

# Make sure your used oil storage tanks ordrums have proper containment in case

there is a leak or spill.# Inspect your used oil storage tanks or

drums on a regular basis for leaks orspills. This is a regulatory requirement.

# Use large drum funnels or fill tubes whenfilling used oil drums.

# If you have to service a boat or otherwater craft on-site, try to prevent spills.Do all servicing on impervious surface. Ifspills do occur, clean up oil spills withrags. After wringing out the saturated raginto the used oil drum, have the ragslaundered with an industrial orcommercial laundry service. See sectionentitled Shop Towels for requirements.

REGULATORY REQUIREMENTSTerne plated oil filters are no longer

manufactured in the United States for use inprivate vehicles. Terne which consist of analloy of lead and tin, is typically a hazardouswaste when disposed. However, non-terneplated used oil filters are not considered ahazardous waste if used oil is removed fromthe filter by one of the following methods:

• Puncturing the filter and hot draining forat least 12 hours at or near engine-operating temperature.

• Hot draining for at least 12 hours at ornear engine-operating temperature andthen crushing the filter.

• Hot draining at or near engine-operatingtemperature and dismantling the filter.

• Any other equivalent method that willremove used oil.

Used oil filters that are not drained byone of the above methods are subject toregulation as used oil.


Used Oil Space Heaters

If one of the above methods has beenperformed, these used oil filters can bedisposed of as nonhazardous solid waste,subject to town and county requirements.However, the most environmentally preferredmethod of disposal is to recycle these filters.Opportunities exist for recycling properlydrained filters and the Department encouragesthe recycling of used oil filters whereverpossible. Check with your local scrap metalyard for more recycling information.


S Crush or puncture the dome or anti-drainvalve and hot drain the filter.

S Collect oil from filter crushing andmanage it the same way as engine usedoils.

S Store drained and crushed filters in aleak-proof container until recycled ordisposed.

S Recycle drained or crushed filters withyour scrap metals.

REGULATORY REQUIREMENTSOperations can burn their own used oil

and used oil from do-it-yourself oil changersin specially designed used oil-fired spaceheaters as long as the following requirementsare met:

• The used oil originates from vehicles,including used oil generated from boats,at your facility or by accepting it fromindividuals (non-commercial) whogenerate the used oil by draining the

lubricating oil out of their own motorizedequipment.

• The heater is designed to have amaximum capacity of no more than 0.5million BTU per hour (Note: You canuse a higher capacity heater, but you willneed a permit).

• Exhaust gases from the heater are ventedto the outside air.

• The used oil has not been mixed with anyhazardous waste.

• You comply with 6 NYCRR Subpart225-2 (Fuel Composition and Use -Waste Fuel). Also, the tanks and/orcontainers used to store used oil mustcomply with the NYSDEC “Used OilRequirements.”Many maintenance operations purchase

used oil-fired space heaters and then find outthat they don’t generate enough used oil tokeep the space heater operating throughout thewinter. Although it may seem desirable toreceive used oil from other sites that generateused oil, both the used oil and air regulationsimpose significant restrictions, such as recordkeeping and analytical testing, on thispractice. If you wish to explore the possibilityof burning used oil from other than your ownor do-it yourself oil changers, please contactthe DEC’s Technical Determination andAnalysis Section of the Division of Solid andHazardous Materials at (518) 402-8612, orcall your DEC’s regional office.

Due to the harmful effects of used oil onthe environment, do not burn used oil in anunapproved boiler, space heater or furnace.


Q I just cleaned up an oil spill withabsorbents and speedy dry. Can I throwthis waste in the dumpster?

A Not without a hazardous wastedetermination. Used oil that is notdestined for recycling or burning forenergy recovery must have a hazardouswaste determination done beforedisposing of the waste. Generallyspeaking, if absorbents or speedy dryhave any free liquids they should not goin the dumpster, even if they are not ahazardous waste. Most oil spills can beavoided. Have your employees use carewhen handling containers that have thepotential to spill. Other spilled chemicalsmay be a hazardous waste as well. If youare in doubt, check with your DECoffice.

Q I just purchased a facility but there are nopublic sewers in my town. There is afloor drain in the middle of my shop, butI am not sure where it empties into. Theonly water that empties into this drain isfrom my operations floor area. Are thereany special regulations that I have tocomply with?

A If your discharge from this floor draindoes not end up in a public sewer orsome type of holding tank, then there is agood chance you are in violation of theEnvironmental Conservation Law (ECL)for an illegal discharge to surface orgroundwaters. You should determinewhere the floor drains discharge by usingsome environmentally safe dye or foodcoloring. Any discharge of wastewaterfrom an industrial operation into the

ground or surface waters of the state isillegal.

Q I am a marina owner and before we paintour boats, the old paint is scraped off andcollected in a tarp. Can I discard mypaint chips in the dumpster? Would itmake it difference if I discard them in atarp?

A Paint chips can be discarded in thedumpster only after you have determinedthat the paint chips are not a hazardouswaste. This means that you must make ahazardous waste determination from yourknowledge, or by performing a toxicitytest on the paint chips (see page 31 ofthis manual). Under no circumstancescan hazardous waste be discarded in adumpster. Wrapping paint chips in a tarphas no affect on disposal options.

Q I generate a wide variety of wastes at mymarina. Are there any hazardous wastesI do not have to count in order todetermine my generator status?

A In order to count your waste, you mustfirst determine which wastes arehazardous. Secondly, you must determineif any of your hazardous wastes areexempt from counting. Note: Do notcount nonhazardous waste. Whendetermining your generator category, youdo not have to count such wastes asuniversal wastes, spent lead-acidbatteries that are reclaimed, used oilmanaged under 6 NYCRR part 360-14and 374-2, solvents that are taken

Some Commonly Asked Questions


directly from an operating machine andput directly into a still for recycling,spent fluorescent bulbs managed underthe universal waste rule, computermonitors or other electronic equipment ifsent to an authorized recycler, or otherwastes that are specifically exemptedfrom counting.

Q I frequently hire several differentcontractors to do work at my marina.Most of the time they leave solvents,paints, and other toxic materials at myfacility when they complete their work.Who is responsible for these materials?

A Any waste materials that are generated atyour marina are essentially yourobligation. You are responsible for thesafe handling and disposal of these items.

Q I own a good-sized marina with amaintenance shop that performs oilchanges on my customer’s boats. Iusually give my used oil to anothermarina located in the same town, and it isburned in their space heater. How muchoil can I transport at one time to thisother marina?

A None, unless he is permitted by DEC toaccept used oil. Assuming this othermarina does not have a permit, (which isa good assumption), both marinas are inviolation of the DEC used oil regulations.You are in violation for illegallytransporting to an unauthorized recycler,and he is in violation for accepting usedoil without a DEC permit. You cant ransport up to 500 pounds(approximately 1 drum) of used oil at onetime to an authorized used oil recyclingfacility.


NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION625 Broadway, Albany, NY 12233

Resource GuideThe following organizations provide technical assistance; publish information; conduct or speak

at workshops and conferences; and provide telephone, written and on-site information to generatorson pollution prevention and better management of air, water, solid and hazardous waste issues.

Division of Environmental Permits(518) 402-9167Responsible for outreach and complianceassistance by offering workshops/training,andpublications.

Division of Solid & Hazardous MaterialsBureau of Hazardous Waste Management(518) 402-8633Responsible for making hazardous wastedeterminations, reviewing hazardous wastereduction plans, hazardous waste permitting,and used oil.

Waste Transporter Program(518) 402-8705Responsible for issuing permits to waste haulersthat transport solid and hazardous,industrial/commercial, sewage and septagewaste.

Bureau of Waste Reduction & Recycling(518) 402-8705Responsible for solid waste recycling and wastereduction issues.

Division of Air ResourcesBureau of Stationary Sources(518) 402-8403

Responsible for source review, permitting,MACT, NESHAP implementation, and air toxicsassessments.

Division of WaterBureau of Water Permits(518) 402-8111Responsible for managing the State PollutantDischarge Elimination System (SPDES)permits, the water resources programs, andthe municipal water supply permits.

Spill Response Hotline(800) 457-7362To report releases of petroleum products orhazardous substances to air, land or water.Regulations require reporting within 2 hoursif certain conditions are not met. Also, theNational Response Center should be notified.

Division of Environmental RemediationPetroleum and Chemical Bulk Storage(518) 402-9549Responsible for the registration ofabove/underground tanks, conductingworkshops and training, and developingpublications for the petroleum and chemicalbulk storage program.

Bureau of Watershed ManagementNonpoint source management section(518) 402-8250Responsible for nonpoint source management,amending water quality standardsregulations, provide water quality evaluationsfor SPDES permits, and develop totalmaximum daily loads for priority waters.


NYSDEC Regional Offices

REGION 1Nassau & Suffolk CountiesBuilding 40 SUNY at Stony BrookStony Brook, NY 11790(631) 444-0375

REGION 2 Bronx, Kings, New York, Queens andRichmond Counties1 Hunters Point Plaza47-40 21st StreetLong Island City, NY 11101(718) 482-4900

REGION 3Dutchess, Orange, Putnam, Rockland,Sullivan, Ulster and Westchester Counties21 South Putt Corners RoadNew Paltz, NY 12561-1696(845) 256-3000

REGION 4Albany, Columbia, Delaware, Greene,Montgomery, Otsego, Rensselaer ,Schenectady and Schoharie Counties1150 North Westcott RoadSchenectady, NY 12306-2014(518) 357-2234

REGION 5Clinton, Essex, Franklin, Fulton, Hamilton,Saratoga, Warren and Washington CountiesRoute 86Ray Brook, NY 12977(518) 897-1200

REGION 6Herkimer, Jefferson, Lewis, Oneida and St.Lawrence Counties317 Washington StreetWatertown, NY 13601(315) 785-2238

REGION 7Broome, Cayuga, Chenango, Cortland,Madison, Onondaga, Oswego, Tioga andTompkins Counties615 Erie Boulevard WestSyracuse, NY 13204-2400(315) 426-7400

REGION 8Chemung, Genesee, Livingston, Monroe,Ontario, Orleans, Schuyler, Seneca, Steuben,Wayne and Yates Counties6274 East Avon-Lima RoadAvon, NY 14414(585) 226-2466

REGION 9Allegany, Cattaraugus, Chautauqua, Erie,Niagara and Wyoming Counties270 Michigan AvenueBuffalo, NY 14203-2999(716) 851-7000


State and Local Assistance

Erie County Office of Pollution PreventionDepartment of Environment and Planning95 Franklin Street, Room 1077Buffalo, NY 14202-3973(716) 858-7674Provides confidential assistance to businessesand the private sector in Erie County.

NYC Department of EnvironmentalProtection, Environmental EconomicDevelopment Assistance Unit59-17 Junction BoulevardCorona, NY 11368(718) 595-4359Provides assistance to small businesses inNew York City.

The Center for Business and IndustrySUNY at Fredonia, Lagrasso HallFredonia, NY 14063(716) 673-3177Provides assistance for businesses located inChautauqua, Cattaraugus, and Alleganycounties.

SUNY BuffaloCenter for Integrated Waste ManagementJarvis Hall, Room 207Buffalo, NY 14260-4400(716) 645-3446Provides R&D support to industries,businesses, and governmental agencies.

Finger Lakes Water Resources Board307 Lake StreetPenn Yan, NY 14527(315) 536-7488Technical assistance

Broome County Division of Solid WasteManagementEdwin Crawford County Office Building44 Hawley StreetBinghamton, NY 13901(607) 778-2250Provides assistance to residents andbusinesses in Broome County.

NYS Environmental Facilities CorporationSmall Business Assistance Program625 BroadwayAlbany, NY 12207(800) 780-7227(518) 402-7462Provides confidential technical assistance tosmall businesses in New York State on issuesregarding the Clean Air Act.

Clean Air Act Small Business OmbudsmanEmpire State DevelopmentSmall Business Division633 3rd Avenue, 32nd FloorNew York, NY 10017 or30 South Pearl StreetAlbany, NY 12245(800) STATENY or (800) 782-8369Provides confidential assistance to smallbusinesses in New York State on issuesregarding the Clean Air Act.

Lake George Park CommissionP.O. Box 749Lake George, NY 12845(518) 668-9347Technical assistance


Federal Assistance

Asbestos and Small Business Ombudsman401 M Street SWWashington, DC 20460Phone: (800) 368-5888Helps citizens, small businesses, andcommunities with questions on all programaspects with EPA.

RCRA/Superfund/EPCRA Hotline401 M Street SWWashington, D.C. 20460(800) 424-9346(202) 557-1938Answer questions on matters related to solidwaste, hazardous waste, or undergroundstorage tanks. Also, can be used to orderEPA publications.

EPA Region II OfficeCompliance Assistance & Program Support290 Broadway, 21st FloorNew York, NY 10007-1866(212) 637-3268Provides compliance and pollutionprevention assistance to EPA Region II areabusinesses.

EPA Region II OfficeDivision of Enforcement and ComplianceAssistance - RCRA Compliance Branch290 Broadway, 22nd FloorNew York, NY 10007-1866Phone: (212) 637-4145In addition to conducting RCRA inspectionson small businesses, this office providestechnical assistance on RCRA related issues.

EPA HeadquartersOffice of Compliance (2224A)401 M St., SWWashington, DC 20460Phone: (202) 564-7076Fax: (202) 564-0009Regulatory, technical, compliance andpollution prevention assistance.

U.S. Department of TransportationHazardous Materials Information CenterOffice of Hazardous Materials StandardsResearch & Special Programs Administration400 7th Street, SWWashington, DC 20590-0001Phone: (202) 366-4488Phone: (202) 366-4000 (Main Number)Technical assistance on matters related toDOT’s hazardous materials transportationregulations.

Pollution Protection InformationClearinghouse (PPIC)PPIC-EPA1200 Pennsylvania Avenue NWWashington, DC 20460Phone: (202) 566-0799E-mail: [email protected] a library and an electronic bulletinboard dedicated to information on pollutionprevention.

National Response Center(800) 424-8802In Washington, D.C. (202) 426-2675To report oil and chemical spills to theFederal Government. This hotline is mannedby the U.S. Coast Guard.


New York State Permitted Household Hazardous Waste Facilities

If you are a Conditionally Exempt Small Quantity Generator and located in one of the followingcounties, you can call the number listed to make arrangements to bring your hazardous waste fordisposal. Appointments are usually required. Some counties are opening their facilities toneighboring counties. If your shop is not located in any of these counties, you may want to callthe closest household hazardous waste collection facility for more details.

Broome CountyDivision of Solid Waste ManagementP.O. Box 1766, Government PlazaBinghamton, NY 13902(607) 778-2250

Oneida-Herkimer Solid Waste Management Authority311 Turner StreetUtica, NY 13501(315) 733-1224

Monroe County444 East Henrietta RoadRochester, NY 14620(716) 760-7600 (option 3)

Rockland County50 Sanitorium RoadP.O. Box 350Pomona, NY 10970(845) 364-2086

Tompkins County Solid Waste Management122 Commercial AvenueIthaca, NY 14850(607) 273-6632(607) 273-HHWM (4496)

Ulster County Resource Recovery Agency1266 Ulster AvenueKingston, NY 12401(845) 336-0600


Trade Associations

Empire State Trades Association. Inc.718 South Shore RoadEdinburg, NY 12134-5929888-I-BOAT-NYSE-mail: [email protected]

New York Sea Grant62B Makin HallSUNY College at OswegoOswego, NY 13126-3599315-312-3042E-mail: [email protected]

New York Sea Grant146 Suffolk HallSUNY at Stony BrookStony Brook, NY 11794-5002

Empire State Marine Trade AssociationAlbany Communications518-465-7085E-mail: [email protected]

National Marine Manufactures Association200 East Randolph DriveSuite 5100Chicago , IL 60601312-946-6200E-mail: [email protected]


Resources on the Internet

Organization Internet Address

New York Marine Trade Association www.nymta.com

NYS Department of EnvironmentalConservation (NYSDEC)NYSDEC-Pollution Prevention Unit

www.dec.state.ny.us

www.dec.state.ny.us/website/ppu

NYS Empire State DevelopmentBusiness Assistance Services

www.empire.state.ny.us

NYS Environmental Facilities Corp. -Clean Vessels Assistance Program

www.nysefc.org/newweb9/cvaphome.htm

NYS Energy Research and DevelopmentAuthority

www.nyserda.org

U.S. Department of EnergyPollution Prevention InformationClearinghouse

www.epic.er.doe.gov/epic

USEPA-Common Sense Initiative www.epa.gov/commonsense

USEPA-Design for the Environment www.earth2.epa.gov/dfore

USEPA-Enviro$en$e www.es.epa.gov

USEPA- Industry Sector Notebooks www.epa.gov/oeca/sector

USEPA-Office of Underground StorageTanks

www.epa.gov/unix0008/water/muni/under.html

USEPA-Small Business AssistanceProgram

www.epa.gov/sbo

USEPA- Technology Transfer Network www.epa.gov/ttn

Tellus Institute www.tellus.org

Waste Reduction Resource Center www.p2pays.org

NY Marine Trades Association www.nymta.com

USEPA- Office of Wetlands, Oceans, andWatersheds

www.epa.gov/owow/oceans/

http://www.nymta.com

http://www.dec.state.ny.us

http://www.dec.state.ny.us/website/ppu

http://www.empire.state.ny.us

http://www.nysefc.org/newweb9/evaphome.htm

http://www.nyserda.org

http://www.epa.gov/commonsense

http://www.epa.gov/unix0008/water/muni/under.html

http://www.epa.gov/sbo

http://www.epa.gov/ttn

http://www.tellus.org

http://www.p2pays.org

http://www.epa.gov/owow/oceans/

http://www.nymta.com

http://www.epa.gov/oeca/sector

http://es.epa.gov

http://earth2.epa.gov/dfore

http://epic.er.doe.gov/epic


NYS Department of State CoastalResources

www.dos.state.ny.us/estl/estlwww.html

New York Sea Grant www.nyseagrant.org

U.S. Fish & Wildlife Service www.fws.gov

NYSDEC Storm Water Phase II Program www.dec.state.ny.us/website/dow/phaseII.html

http://www.nyseagrant.org

http://www.fws.gov

http://www.dec.state.ny.us/website/dow/PhaseII.html

http://www.dos.state.ny.us/cstl/cstlwww.html


Green Products Websites

Green ProductsThe NYSDEC does not endorse any vendors or services mentioned in this section.

www.procara.ca Welcome to Procara, a powerfuldatabase designed for procurementprofessionals, purchasers or individualsseeking to lessen the environmental impactsof their purchasing decisions. The Databaseis accessible to all users free of charge overthe Internet via this Database Search page.

www.greenpurchasing.caWelcome to GreenPurchasing.ca. This

web site, a service of the Centre forIndigenous Environmental Resources(CIER), is here to provide generalinformation about green purchasing.

www.buygreen.comRecycling, Energy Efficiency, Water

Conservation, Pollution Prevention. Theseare all objectives of environmentallypreferred, environmentally responsible orenvironmentally sound procurement orpurchasing. This home page is dedicated toproviding information on "green" productsand services, and tips on how you can set upa green procurement program.

www.oecenvironmental.com/index.htmlEliminate Dangerous Chemicals!

R e d u c e E m p l o y e e R i s k ! O E CEnvironmental, Inc. is a leader in the field fors u p p l y i n g S A F E R a n d m o r eENVIRONMENTALLY friendly cleaners,degreasers, parts washers, lubricants, andmany other products for use in industry.

OEC has been recognized for its'commitment to providing industry with saferalternatives to the many hazardous and toxicsubstances typically found in the industrialworkplace.

www.biocleannj.comBIOCLEAN, Ltd. is an authorized

distributor of Spillaway bio-remedialproducts formulated by the EnviroLogiccorporation - a world leader in the field of bio-remedial technology. EnviroLogicproduces the widest range of products in thisfield. Bio-remediation will remediatehydrocarbons on any surface: concrete,fiberglass, wood, asphalt, soil, water...anysurface!!!

Bioremediation is an amazingtechnology that eliminates hydrocarboncontamination with a natural processutilizing nature's own micro-organisms todigest and degrade the hydrocarbon,. Thisprocess transforms the hydrocarbon intoharmless carbon dioxide and water with littleor no disruption of surrounding areas.Because no volatile chemicals are used, thereis no air pollution and no health or safetyrisks. BIOCLEAN, Ltd., 628 Wishing WellRoad, Wyckoff, NJ 07481, toll free 866-232-3996; phone 732-774-6770; fax 732-774-6699.

www.swmcb.org/publications/index.htmlEnvironmentally Preferable Purchasing

Guide (2000). The EnvironmentallyPreferable Purchasing Guide providesgovernment purchasers with information onpurchasing environmentally preferable

www.buygreen.com

http://www.oecenvironmental.com

http://www.biocleannj.com

http://www.swmcb.org/publications/index.html


Products

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SIMPLE GREENNon-Hazardous Cleaning Products Safer

Alternative To Hazardous Chemicals andsolvents. For years, Simple Green has

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PAINT STRIPPERThe AmeriStrip ® paint stripper is a

biodegradable, water washable non-causticand methylene chloride free gel that iseffective in removing lead-based paints,latex, alkyd, varnish, polyurethane and epoxyresin coating from structural metal, cement,fiberglass, wood, mica, and plaster. In short,if you need to remove almost any kind ofpaint from almost any type of material,AmeriStrip will do the job. AdditionalApplications include: marine applicationsand refurbishing: hull stripping, detail andtr im, wood, f iberglass, gelcoat .www.ameristrip.com/benefits.html

ENVIRO-BOND HYDROCARBONPOLYMER

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SHRINK WRAP RECYCLERS• Buffalo Shrink Wrap, 11342 Main

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• Dr. Shrink, 1606 State Street, Manistee,MI 49660-1855, (800) 968-5147.

http://www.shakelight.com

http://www.ameristrip.com/benefits.html

http://www.enviro-bond.com


Best Management Practices

• Dockside Boat Reconditioning, Inc.,Rhode Island, (401) 351-7130 and800-898-7206 - For $9.95, they will sellyou a large plastic bag to put theshrinkwrap in, and cover the cost ofhaving Roadway Package Systems pickit up and take it to Ecologix in Holland,Mich., to be recycled into otherproducts.

DURABOARD (TM)A virtually indestructible and

completely non-toxic construction materialthat can be use for decking. It’s made fromdiscarded automobile tires and contains noharmful chemicals or heavy metals such ascopper, chromium and arsenic. TireConversion Technologies, Inc., 605Corporations Park, Scotia, NY 12302; (518)372-1300; Fax (518) 372-5505; email:[email protected]

PlasTEAKRecycled plastic lumber and products.

PlasTEAK Inc., 3563 Copley Road, PO Box4290, Akron, OH 44321; 1-800-320-1841;website: www.plasteak.com.

Using Environmentally FriendlyProducts

S use propylene glycol antifreeze towinterize all systems except “closed,” orfreshwater cooling systems. It’s muchless toxic than ethylene glycolantifreeze.

S use water-based, non-VOC cleaners thatare less hazardous than solvent-baseddegreasers. They are less toxic and non-flammable.

S use phosphate free, biodegradable andnon-toxic soap when prepping a hull.

S use low-VOC, high solids content andwater-based paints and surfacepreparation products instead oftraditional paints and primers.

S use of non-toxic, high bonding, andeasily cleaned hull coatings isencouraged.

S use paint strippers which are soy-basedor water-based products, which are lesshazardous.

S use long-lasting, low-toxicityantifouling paint.

S use dustless or vacuum sanders whensanding, which can collect over 98% ofdust generated instead of releasing itinto the air.

S use mild, phosphate-free detergent withbronze wool to clean teak instead ofcaustic or acidic teak cleaners.

S use an oil/water separator to remove oilfrom bilge water.

S use biodegradable and non-toxic holdingtank deodorant.

http://www.plasteak.com


NON-TOXIC CLEANING ALTERNATIVES

The following provides non-toxic alternatives to typical cleaning products. It should benoted that even non-toxic substances can cause temporary harm to the environment andis recommended they be use sparingly.

All Purpose Cleaner Mix one cup white vinegar with two gallons water

Air Freshener Leave out an open box of baking soda

Ammonia-basedcleaners

Vinegar, salt, and water

Brass Cleaner Worcestershire sauce; or paste made with equal amounts of salt,vinegar, and water

Copper Cleaner Lemon juice and water; or paste of lemon juice, salt, and flour

Chlorine Bleach Baking soda and water; or borax

Chrome Cleaner/Polish Apple cider vinegar to clean; baby oil to polish

Disinfectants One half a cup borax in one gallon of water

Drain Opener Dissemble and use a plumber’s snake; or flush with boilingwater mixed with one quarter cup baking soda and one quartercup vinegar

Fiberglass stain remover Baking soda paste

Floor Cleaner One-cup vinegar plus two gallons of water

Paints Use latex or water-based paints

Paint Remover/Stripper Use heat gun to peel off paint

Paints Thinners Use water (effective for water-based paints)

Stainless Steel Cleaner Baking soda or mineral oil for polishing, vinegar to remove spots

Toilet Bowl Cleaner Use toilet brush and baking soda

Wood Polish Olive or almond oil (interior walls only)

Window Cleaner Mix two tablespoons vinegar in one quart of water or rub glasswith newspaper

Source: Buller, Pat (1995) Clean Marina + Clean Boating + Clean Water Partnership. Seattle, WA; and MADepartment of Environmental Management, Environmental Hazards Management Institute.

Environmental Compliance, Pollution Prevention, and March 2003Self-Assessment Guide for the Marina Industry

NOTES

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