logo Small Shipyards and Boatyards in Oregon: Environmental Issues & P2 Opportunities
A Northwest Industry Roundtable Report

 

Introduction

The Pacific Northwest Pollution Prevention Resource Center (PPRC) held a roundtable discussion on November 10, 1997 in Coos Bay, Oregon on pollution prevention issues facing the Oregon shipbuilding and repair industry. More than one dozen representatives of commercial shipyards and boatyards, port authorities, the Oregon Department of Environmental Quality and PPRC attended.

 

Reasons for the Roundtable

The roundtable was held at this time for the following reasons:

  • The construction, maintenance and repair of marine vessels is an important component of Oregon's coastal and Columbia River economies. Industries served by shipyards include sport and commercial fishing, pleasure boating, tug and barge services, and industries engaged in international trade, such as forest products, agriculture, tourism and technology.
  • Shipyards rely on processes that generate considerable releases to air and water, and generate solid and hazardous wastes. Heavy metals found in anti-fouling paints, spent paint removal blasting grit, process and bilge water, solvents, oily wastes and waste engine fluids are among the potential pollutants of concern.
  • The industry is under close regulatory scrutiny and faces compliance requirements related to hazardous wastes, wastewater, stormwater, and air emissions generated by vessel construction, maintenance and repair activities.
  • Technologies and practices that reduce wastes have been investigated or are being implemented by a number of shipyards, providing an opportunity for information sharing about pollution prevention alternatives among industry peers.
  • The goals of the roundtable were two fold: 1) To provide a forum for participants to share useful information about pollution prevention processes and practices, and 2) To generate ideas for future projects that will facilitate the incorporation of pollution prevention into shipyard activities.

     

    Shipyard Roundtable Projects

    The Coos Bay roundtable was the second in a series of three roundtables PPRC has sponsored for the shipyard industries of Oregon and Washington. Shipyards in both states face similar environmental and economic issues that can be addressed through pollution prevention. The Coos Bay roundtable focused on small shipyards and boatyards. The other two roundtables focused on larger shipyards. A roundtable for shipyards in the Puget Sound region was held in May 1997, and the roundtable report (refer to Large Shipyards in Washington: P2 & BMP Opportunities) was published in September 1997. A roundtable for Portland-area shipyards was held in December 1997.

     

    Oregon Shipbuilding and Repair Industry

    Background

    The shipbuilding and repair industry is part of the basic infrastructure of Oregon’s coastal and Columbia River economies. In 1995, the last year for which U.S. Census data is available, there were 20 shipbuilding and repair facilities in Oregon with an annual payroll of nearly $35 million. There were 52 boatbuilding and repair facilities with an annual payroll exceeding $21 million.

    Shipbuilding and repair facilities are located along the coast from Astoria south to Brookings, and along the Columbia River. They provide a varied range of services, including new vessel construction; hull cleaning, repair and painting; metal fabrication and machining; electrical equipment maintenance and installation; carpentry and joining; piping; outfitting; and propulsion system work for fishing vessels, tugboats, barges and other work boats.

    Port authorities are closely related to shipyards as basic components of Oregon’s coastal and Columbia River economies. They provide services and carry out improvements to facilitate the movement of commercial goods and passengers. There are 23 public ports in the state, along the coast from Astoria south to Brookings and along the river east to Umatilla. A number of ports offer facilities for private ship repair and maintenance. Ports generate approximately 22,000 jobs and $3.5 billion in business revenues annually. They support industries such as fishing, agriculture, forest products, technology and tourism.

    Environmental Issues

    Shipbuilding and repair facilities pose special environmental concerns because of the processes and materials they use, and because of their proximity to bodies of water. Removal of hull coatings and painting operations can result in both water and air emissions, and significant quantities of hazardous and solid wastes. In particular, aquatic organisms such as shellfish are at risk from "anti-fouling" pesticides found in hull bottom coatings. Other activities that can result in discharges and waste generation include vessel cleaning, engine maintenance, fueling and bilge water pumping. Worker exposure to chemicals found in hull coatings is an additional concern.

    Hull Stripping and Painting: The buildup of barnacles and other marine organisms onto hulls can greatly reduce vessel fuel efficiency and speed. The bottoms of vessels that have prolonged seawater contact commonly are coated with "anti-fouling" paints containing pesticides that inhibit the attachment of fouling organisms to hulls. The active ingredients commonly found in anti-fouling paints are metal-based: cuprous (copper) oxide or tributyltin (TBT). The pesticides are harmful to non-targeted marine life as well as fouling organisms. Metals can enter the water column and bottom sediments through sloughing of paint while vessels are in use, and through discharge of anti-fouling paint chips and paint removal materials during vessel maintenance activities.

    Studies have shown that TBT causes adverse reproductive effects on shellfish at low levels. Concerns about TBT's potency resulted in a 1989 federal law banning TBT for all non-aluminum vessels less than 25 meters in length. The Navy stopped using TBT coatings altogether. The partial ban, however, did not resolve concerns about the impacts of anti-foulants. Under federal law, TBT may still be used on larger civilian vessels and on aluminum boats. U.S. law does not apply to vessels that are coated overseas and call on U.S. ship repair facilities for hull maintenance activities.

    When a ship's hull is prepared for painting, the process typically starts with pressure washing to remove attached marine organisms and slime. Next, the hull is stripped by blasting off old paint with an abrasive grit. Smaller vessels can be worked on beneath shop roofs, but larger vessels must be worked on outside, on floating drydocks or marine railways. Blasting grit used at south coast shipyards typically is a slag that is a byproduct of ferronickel production at a Riddle, Oregon smelter. The constituents of blasting grit vary, but in general include oxides of silicon, iron, aluminum and calcium. Some grits also may contain oxides of zinc and magnesium, and trace amounts of copper, titanium, sulfur, and oxides of potassium and sodium.

    Paint stripping jobs require varying amounts of grit, depending on vessel size and hull surface condition. In many cases, however, a considerable quantity will be necessary. Stripping 3,000 square feet of hull surface area, for example, may require an estimated 60 tons of grit. All Oregon shipyards together use an estimated 400,000 tons of grit per year. The large quantities make management and disposal of grit a critical economic and environmental issue for shipbuilding and repair facilities.

    After use, both the pressure wash water and grit contain paint chips laden with anti-foulants, which can reach nearby waterways via stormwater drainage, flooding of a marine railway, or airborne migration of grit out of blasting or storage areas. Abrasive grit blasting also generates significant volumes of fine airborne dust that can be difficult to contain. Spent grit that "fails" toxicity tests must be managed and disposed of as hazardous waste. Under Oregon law, if grit 'fails" either the Toxicity Characteristic Leaching Procedure (TCLP) test or an aquatic toxicity test, it is considered hazardous waste. The likelihood that grit will fail the tests depends on how it has been used. Grit that has been used to remove anti-fouling bottom paints is more likely to fail the tests than grit that has been used to depaint topside surfaces.

    Solvents commonly are used to formulate both bottom paints and coatings used for topside applications such as corrosion resistance. Solvents are sources of hazardous waste and of volatile organic compounds (VOCs). These compounds include Hazardous Air Pollutants (HAPs) regulated under the 1990 amendments to the federal Clean Air Act. On December 15, 1995, the U.S. EPA finalized a rule covering emissions of Hazardous Air Pollutants (HAPs) from shipbuilding and ship repair surface coating operations. Facilities that have the potential to emit 10 tons of any one hazardous air pollutant or 25 tons of any combination of such pollutants are considered a major source, and are responsible for controlling emissions under this standard. (Refer to Appendix B for a summary of environmental laws affecting shipyards.)

    Painting and improper storage or disposal of paint containers also can result in solvents and anti-foulants entering nearby waterways.

    Other Waste Liquids: Wash water, oily water from bilges and tank cleaning, and engine fluids such as oil, hydraulic fluids, lubricants, and anti-freeze are among the waste liquids generated by shipyard activities. Fueling facilities are another potential generator of waste liquids. Hydrocarbons, glycols and other pollutants in these liquids can come into contact with waterways and aquatic life through spills and leaks.

    Summary of Pollution Prevention Alternatives

     

    Roundtable Discussions

    This section includes a summary of topics discussed during the roundtable meeting. The following information represents the opinions of roundtable participants, and may not reflect the views of all Oregon shipyards and boatyards.

     

    Pollution Prevention Issues

    The following subsection includes discussions of key concerns surrounding pollution prevention issues, and descriptions of waste reduction and prevention projects that have been undertaken by Oregon shipyards and boatyards.

    Paint Stripping Grit Management and Disposal

    Key Issues
    For many, if not all of the roundtable participants, the management and disposal of paint stripping grit is a critical cost management issue. Grit blasting long has been the paint stripping technology of choice in the shipbuilding and repair industry. Grit is widely available and economical, effectively removes paint, and sets a proper “surface profile” for painting. Without a local reuse option such as cement manufacturing, grit containing anti-foulants must be sent to permitted hazardous waste facilities. That represents a substantial cost for south coast shipyards because of the facilities’ considerable distance. As a practical matter, all spent grit, even material that does not “fail” toxicity tests, has to be sent to the hazardous waste facilities. Non-hazardous waste disposal sites are reluctant to accept any spent blasting grit, regardless of whether it passes toxicity tests or not.

    Spent grit that contains anti-foulants can be sent to cement kilns, as is the practice among several Washington shipyards, but there are no such facilities conveniently available to south coast shipyards. Oregon Department of Environmental Quality (DEQ) has investigated grit reclamation, but the idea did not prove fruitful because the grit manufacturer did not believe there was enough recoverable material. Another idea raised in discussion was for the state to establish a facility to handle spent grit and other shipyard wastes. But DEQ representatives indicated that private disposal facilities would object to the state getting into their business.

    Shipyard Projects and Practices
    • Sand Reuse: At Fred Wahl Marine Construction, grit is used up to three times before it is spent, which reduces costs an estimated 17 percent. Spent grit containing anti-fouling paint chips is kept separate from spent grit used on bare metal or to remove topside paints that don’t contain anti-foulants. Grit is tested after each use with the TCLP test, at a cost of $150 per test.

      The shipyard is building a 750-square-foot storage facility with three bins that will hold 20 tons of sand each. The bins will be used to separate grit that has “failed” toxicity tests from other grit. So far, however, the shipyard has not been able to find a conveniently located non-hazardous waste disposal facility that will accept spent grit that has passed toxicity tests. All spent grit is disposed of as hazardous waste, at a cost of $52 to $54 per ton. Consequently, the shipyard has not reaped any economic benefit from separating grit.

    • Blasting Containment: International Contractors is constructing an enclosed building for grit blasting. The building will be equipped with air filtration and a wet scrubber. The roof will have a split configuration to accommodate vessels with tall superstructures.

    Alternative Paint Stipping Methods

    Key Issues
    A number of alternative paint stripping methods are available that avoid the management and disposal issues associated with dry, abrasive grit. Among the alternatives are blasting with high-pressure water, wetted grit and steel shot. Issues raised about the alternatives during discussion included costs, operating characteristics and effectiveness. For example, participants expressed concerns that high-pressure water blasting may not set a satisfactory "surface profile" on the bare metal substrate, which is necessary for new coating to adhere properly to hulls. In response to wetted grit blasting, participants raised concerns about grit cleanup and increasing wastewater streams. Another potential barrier to the use of wet blasting processes is "flash rust" that appears on stripped metal substrates exposed to the elements after blasting.

    The advantages and disadvantages of other alternative paint stripping media were outlined. They include:

    Plastic
    Pros: Media can be used 10 to 12 times, and there is no wastewater to dispose of.
    Cons: Capital costs for blasting and media recycling equipment are high, spent media must be disposed of as hazardous waste, stripping quality depends on operator skill.

    Sponge Blasting
    Pros: Media can be used 10 to 15 times, media is safe and transportable.
    Cons: Both capital and media costs are relatively high.

    Wheat Starch
    Pros: Media is plentiful, and waste totals only 5 percent of the input volume.
    Cons: Initial capital costs are high, complex media recovery systems are necessary, media is moisture sensitive.

    Carbon Dioxide
    Pros: Blasting media vaporizes after use, provides excellent surface preparation.
    Cons: Multiple passes may be needed to fully remove paint, capital costs can be high, system may cause worker fatigue.

    Shipyard Projects and Practices
    • Steel Shot: Southern Oregon Marine has used a type of push cart that blasts steel shot onto barge decks, then collects the shot and coating dust. The apparatus effectively removes coatings down to bare metal, but is only practical to use on open, flat decks.

    • Deck Scaler: Sundial Marine Tug and Barge Works has used a deck scaler that uses miniature hammers to pulverize coating. The machines were not expensive to purchase, but required extensive maintenance at the end of each work shift. Another drawback was machine noise.

    • Debonding Experiment: Riverbend Marine Services tried a non-toxic paste product for removing bottom paint, but the results were unsatisfactory. The material was applied, left on the hull for a time, then peeled off, which was supposed to remove the coating. Upon peeling, however, the product did not remove all the paint, possibly because it is better suited for warm climates. The stripping job had to be finished with grit blasting.

    Alternative Coatings

    Key Issues
    Coating choices are driven by issues such as cost, effectiveness in retarding the buildup of marine organisms, customer specifications, price-competitiveness, and availability of information. Alternative anti-fouling coatings that do not leach pesticides into seawater or don’t rely on pesticides at all are available, but cost can be a significant barrier to use. Concern about product effectiveness is another barrier. For example, one of the points raised in discussion is that products with low levels of volatile organic compounds (VOCs) are less durable than high-VOC coating products.

    Paint based on pure metallic copper instead of cuprous oxide is one of the alternative anti-fouling products. The paint is formulated by embedding pure metallic copper into epoxies, a process which prevents the metal from leaching into seawater. Other alternatives include coatings that use zinc oxide as an anti-foulant, and silicone-based slippery paints that rely on surface properties rather than pesticides to prevent marine organisms from attaching. The use of cayenne pepper as a possible anti-foulant was mentioned, but none of the roundtable participants reported trying a cayenne-based anti-fouling product. Peppers from the genus Capsicum contain capsaicin, the oil which gives peppers their heat. At least one capsaicin-based bottom paint is commercially available.

    Roundtable participants expressed interest in learning more about alternative anti-foulants directly from coatings dealers. Shipyard representatives indicated they would be willing to pass the information on to customers.

    Alternative painting equipment is a related pollution prevention alternative. The use of conventional air spray guns can result in 70 percent to 85 percent of the applied paint going to waste through overspray, which generates air emissions and hazardous waste. Alternatives that reduce paint waste include high-volume, low-pressure (HVLP) spray guns, airless guns, and air-assisted airless guns. HVLP guns shoot paint at low velocities, which reduces overspray and results in 50 to 60 percent of the applied paint adhering to the work surface. Airless and air-assisted airless guns rely on hydraulic pressure. They are somewhat less efficient with paint than HVLP guns, but can cover work surfaces more quickly.

    Shipyard Projects and Practices
    • Asphalt for River Barges: Sturgeon Bend Boat Works coated a river barge with common driveway asphalt, using airless spray gun equipment. Since the barge travels slowly, there was no concern about hull fouling, so there was little need to use anti-fouling paint. A potential concern with asphalt is discharge of hydrocarbons into the water when the material breaks down.

    • Painting Equipment: International Contractors and Sundial Marine Tug and Barge Works use airless spraying guns. Fred Wahl Marine Construction has investigated converting to HVLP guns. While the yard’s painters believe HVLP guns would be more manageable, the yard rejected conversion based on costs.

    • Avoiding Coatings When Appropriate: Sundial Marine Tug and Barge Works cautions customers against unnecessary application of anti-fouling bottom paint. Green scale buildup may be sufficient for protecting hull bottoms on river boats.

    Other Waste Liquids

    Key Issues Managing wash water, bilge water, oily wastes and engine fluids can present numerous challenges. They include preventing the mixing of different wastes, and guarding against spills and leaks into nearby waterways. One pollution prevention alternative is closed-loop recycling of process water. Polymer-based systems that include a storage tank and a filter press to dry collected sludge cost approximately $10,000. Another alternative presented was collection of engine oils and hydraulic fluids for removal by recyclers. The risks of fuel spills and leaks can be greatly reduced through the use of “just-in-time” procedures that eliminate on-site fuel storage facilities.

    An idea brought up in discussion was for shipyards to contract for a cost-shared, local pickup service to haul away bilge water and other wastes.

    Shipyard Projects and Practices
    • Closed Loop Process Water Recycling: Sturgeon Bend Boat Works sends wash water to a holding tank for reclamation and reuse. In a 15-minute process, a clay-based substance added to the tank captures solid wastes, then settles to the bottom as a sludge. A pullout tray at the bottom of the tank is then removed to collect the sludge for disposal. The cost of the entire installation was approximately $7,200. As a result of installing the system, the boatyard no longer needs a state wash water permit.

      Sundial Marine Tug and Barge Works rejected installation of a closed-loop washing system five years ago based on costs. As a fallback measure, the shipyard installed a wash water filter with a medium similar to stocking hose in order to filter out paint chips.

      Fred Wahl Marine Construction has designed a process water catch system that includes a settling basin, but has not implemented the project because of costs.

    • Waste Oil Collection: Fred Wahl Marine Construction stores waste oil, bilge water and anti-freeze in separate containers on concrete pads and contracts with a recycler to haul the liquids away. The waste oil is hauled free of charge. The cost of hauling the bilge water is 48 cents per gallon and for anti-freeze the cost is 51 cents per gallon. Fred Wahl also has installed a system to prevent stormwater that collects in the waste oil storage area from reaching receiving waters. The stormwater is directed to a sump, then pumped to the bilge water storage container.

      Fred Wahl found that assigning responsibility for managing waste liquids storage to two trained employees has worked well to prevent spills and mixing of different liquids.

      The International Port of Coos Bay is investigating the purchase of an oil-water separator. Recovered oil will be sold to earn revenue and avoid disposal costs.

    • Just-in-Time Fuels Management: Sundial Marine Tug and Barge Works has implemented a “just-in-time” fuels management system. All on-site fuel storage tanks were decommissioned and the shipyard contracted with a fuels service to serve its customers. The system has reduced spill risks and eliminated the risk of leaks from underground fuel tanks.

    • Vegetable-Based Fluids: Equipment used at Riverbend Marine Services contains hydraulic fluids formulated with vegetable oils.

    Educating Customers and Employees

    Key Issues Influencing the attitudes and behavior of customers, especially in self-help facilities, is a significant factor in preventing pollution and adhering to Best Management Practices. Shipyards encounter a range of customer attitudes about environmental issues. At one end of the range is indifference to the impacts of careless practices. Economically stressed customers have little interest in pollution prevention alternatives that have higher up-front costs. At the other end of the range are customers who are concerned about environmental impacts and are curious about pollution prevention alternatives. A concern raised in discussion was losing customers to less environmentally responsible facilities that could underprice facilities that follow Best Management Practices rigorously and implement prevention projects.

    Employee training is critical if shipyards are to consistently adhere to Best Management Practices. Barriers that shipyards have encountered include lack of employee interest and resistance to changing old practices. Another barrier is the cost of training, because production must be halted to make time for it. Managers also must deal with shipyard owners skeptical of environmental and health concerns related to anti-foulants, air emissions or worker exposure to chemicals.

    Shipyard Projects and Practices
    • Education: The Port of Brookings requires self-help customers to read and sign a statement that they will not engage in specified harmful actions. The port authority provides a paint can drying shed as a service to customers.

    Information Opportunities and Barriers

    Key Issues Participants agreed that lack of consistent information exchange is a barrier to implementing pollution prevention. South coast shipyards do not have a local trade association to keep members informed about issues and developments of interest to the industry. Participants expressed interest in forming or joining a trade association, but one potential obstacle is the cost of membership dues. An existing association that could provide useful information services is American Waterways Operators, which is a national association for tugboat and barge industries. Another is the National Shipyard Association. (Refer to Appendix C for a listing of contacts in marine trade associations.)

    A related issue is difficulty understanding environmental regulations and government reports written with technical and/or legal terminology. Participants expressed interest in having a document that would synthesize and clarify regulatory requirements.

    Weather Conditions

    Key Issue Roundtable participants said it would not be practical to prohibit blasting during windy conditions, as some BMP lists recommend, because windy conditions are common on the coast during the winter. Containment tarping often has proved to be ineffective along both the coast and Columbia River because of high winds. (Refer to Appendix C for a summary of contacts and information resources on BMPs.)

    Summary of P2 Practices Used at Oregon Shipyards

     

    Department of Enviromental Quality (DEQ) Issues

    A brief period was set aside at the roundtable for participants to discuss permitting and regulatory issues with DEQ representatives. Issues of concern were: 1) technical assistance, 2) permitting issues, and 3) an EPA project to assess contamination in waterways and bottom sediments adjacent to shipyards.

    Technical Assistance

    DEQ has received an Environmental Protection Agency grant to provide technical assistance to shipyards, which will focus on Best Management Practices involving blasting grit and paint chips management, stormwater and process water. Followup inspections will be conducted to see how many recommended measures have been implemented.

    The department is drafting a Best Management Practices guide for shipyards and boatyards (Refer to Appendix).

    Permit Issues

    DEQ is investigating multi-media shipyard permits that would consolidate requirements related to air quality, water quality and waste in one permit, and would include enforceable Best Management Practices. The Oregon Attorney General’s office has responded favorably to the concept. Another option being investigated is a stormwater permit with enforceable BMPs. Under current policy, BMPs are provided to shipyards as guidance for complying with water quality, air quality, hazardous waste and solid waste statutes.

    EPA Site Assessments

    In response to shellfish closures prompted by TBT contamination concerns, EPA has begun conducting site assessments of waterways adjacent to coastal shipyards to assess the amount and types of contamination present and identify remediation priorities. EPA began the assessments on the south coast and will continue northward on the coast and on the Columbia River.

    Roundtable participants raised concerns about the accuracy of samples that prompted the assessment reports, the complexity of the reports, and the expenses they have incurred hiring consultants to analyze and clarify them. The expense, they believed, absorbed funds that potentially could have been spent implementing pollution prevention opportunities.

    In response, DEQ representatives said prevention activities will help avoid future cleanup problems, but cautioned that standards may change in the future as information changes.

     

    Information Resources Used by Shipyards

    Information sources that shipyards commonly rely upon are useful channels for disseminating ideas, case studies, research results, contacts and other information pertinent to pollution prevention.

    Sources cited by roundtable participants include:

    None of the participants reported using information available from military sources on pollution prevention technologies and practices.

     

    Recommendations

    As part of all industry roundtables, PPRC identifies projects and other activities to address information needs or waste management issues discussed at the roundtables. Followup projects and activities that could assist Oregon shipyards and boatyards with pollution prevention efforts include the following:

    Continue to Appendix A: Roundtable Attendees.

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    © 1999, Pacific Northwest Pollution Prevention Resource Center
    phone: 206-352-2050, e-mail: office@pprc.org, web: www.pprc.org