Shipyards and Surface Coating Operations
- Facilities that build, convert, or alter ships. The term "ship" means any marine or fresh-water vessel, including push (barges), self-propelled vessels, and navigational aids (buoys). Some of the hazardous air pollutants (HAPs, or air toxic chemicals) emitted by the facilities covered by air regulations include xylene, toluene, ethylbenzene, methyl ethyl ketone, methyl isobutyl ketone, ethylene glycol, and glycol ethers.
- Structural steel fabricators, tank fabricators, and just about any metal coating/painting facility are also affected by most of the rules mentioned below.
- Also see Regulations in a Nutshell for Abrasive Blasting.
Regulations in a nutshell:
- Shipyards typically are regulated sources of the following:
- Painting: Volatile Organic Compounds (VOCs), Hazardous Air Pollutants, (HAPs), and some PM10 (floating dust particles 10 microns in diameter) from overspray
- Abrasive Blasting: PM10
- Fuel Combustion (from stationary compressors and welding machines): Nitrogen Oxides (NOx), Sulfur Oxides (SOx), Carbon
- Monoxide (CO), VOCs, PM10, and some HAPs
- Cutting and Welding: PM10, HAPs
- Fuel Storage: VOCs
Air Regulations Affecting Shipyards and Coating Facilities
- Those with potential-to-emit (based on maximum possible site activity) over 5 tons/year of ANY regulated pollutant, or 15 tons/year of ALL regulated pollutants, or over the Minimum Emission Rate (MER) of any air toxic chemical MUST have an air permit. Application and Emission Inventory Questionnaire (EIQ) forms are available on the DEQ webpage under FORMS.
- A National Emission Standard for Hazardous Air Pollutants (NESHAP) rule applies to shipyard major sources of air toxics (or HAPs). A major source for air toxics is any facility that emits at least 10 tons/year (tpy) of any single HAP, or 25 tpy of all HAPs combined. The NESHAP rule can be avoided if the source becomes a "synthetic minor" by accepting enforceable permit restrictions that ensure potential and actual HAP emissions will be below major source thresholds.
- VOC limits in coatings apply (see LAC 33:III.2123). For shipyards this typically means coatings must not contain more than 3.5 lbs/gallon of VOC as applied. Limits vary by use according to 2123.C.
- Painting facilities must have a WRITTEN housekeeping plan to control VOCs (see LAC 33:III.2113). Typically this means containers (paint, thinner, solvent, fuels, paint waste, etc) must be closed when not in use and spills must be cleaned up.
Facilities that paint and/or use abrasive blasting must control dust/overspray leaving the property (see LAC 33:III.1305).
- Above-ground tanks less than 40,000 gallon capacity containing hydrocarbons with a vapor pressure 1.5 psia or greater must have at least a submerged fill pipe (see LAC 33:III.2103.A).
- Bilge water from boats
- Storm water
- Ballast water from floating docks
- Sanitary waste water
Water Regulations Affecting Shipyards and Coating Facilities
- In general, ANY wastewater discharge to state waters requires an LPDES permit from DEQ, including ambient uncontaminated water pumped in and out of a floating dry dock. DEQ may issue an individual permit or general permit coverage depending on the complexity of the facility. Wastewater discharge permit application forms are available on the DEQ webpage under FORMS.
- Facilities with above ground storage tanks (fuels, oils, chemicals, flowing powders) over threshold capacity (single over 660 gallons OR a collection of tanks & containers, 5 gallons or more, over 1320 gallons) that might impact waters of the state (in the event of a leak, spill or rupture) must have a Spill Prevention & Control (SPC) plan according to LAC 33:IX.901.
- Facilities with above ground storage tanks (fuels and oils) over threshold capacity (single over 1320 OR a collection of tanks & containers, 55 gallons or greater, over 1320 gallons) that might impact navigable waters (in the event of a leak, spill, or rupture) must have a Spill Prevention, Control, and Countermeasure (SPCC) plan according to 40 CFR 112 (federal rule).
NOTE: the state rule is much broader in applicability whereas the federal rule has stricter requirements. Where both apply, the federal rule usually encompasses the state rule requirements.
- Paint clean-up waste
- Fuel tank sludges
- Spent abrasive containing lead, cadmium, or chromium
Hazardous Waste Regulations Affecting Shipyards And Coating Facilities
- These facilities most commonly generate paint clean-up waste which can be hazardous for certain chemicals (listed waste) and/or for flammability (flash point less than 140 degree F, characteristic waste). Generators of any hazardous waste must register with DEQ for an EPA identification number (using HW-1 form available on FORMS page of the DEQ website), properly manage the waste on-site according to their generator class (conditionally exempt I, small quantity II or large quantity III), and keep manifest records of waste sent off-site for disposal.
Non-Hazardous Industrial Solid Waste
- Spent abrasive
Non-Hazardous Industrial Solid Waste Regulations Affecting Shipyards and Coating Facilities
- Typically shipyards and surface coating facilities generate spent abrasive which is most often non-hazardous. However, the generator is always responsible to determine (by process knowledge or testing) if it is hazardous. For example, removing lead, cadmium, or chromium based paints can produce spent abrasive that might be hazardous waste which must be managed and disposed properly. Non-hazardous spent abrasive must either be disposed to a landfill OR beneficially re-used on site (ex. fill in holes) with written DEQ permission.
Reporting and Record Keeping:
- All sources of air emissions, permitted or otherwise, should keep monthly records of what they use (tons of abrasive, gallons of fuel, gallons of each paint/solvent/thinner) and the resulting emissions. Some permits require annual emission reports to DEQ.
- All waste water discharge permits require periodic waste water testing and reporting to DEQ. Some also require preparing and maintaining pollution prevention plans.
- Tier II Hazardous Material Inventory Report: Any facility that keeps at least 500 lbs of any hazardous material on site (fuel, paint, solvent, oxygen, welding gasses, etc.) on any day of a calendar year must annually report their hazardous material inventory to the state police, local fire district, and the local emergency planning committee (LEPC) by March 1st. The state police Tier II website is at www.dps.state.la.us/lcnweb.nsf.
- December 16, 1997, is the compliance date for the NESHAP air rule.
- Keep all solvent and solvent containing liquids in covered containers.
Pollution Prevention Suggestions:
- Use low solvent or solvent free paints and coatings when possible.