Joel Salter, US EPA Office of Water - NPDES from a Federal PerspectiveSalter explained the permiting system set up for Shipyards and Drydocks. Under the Clean Water Act, facilities must obtain permits for
discharge of any pollutants. Such permits are governed by State regulations, with EPA approval.
Permits are generally granted for 5 year terms. They will determine for each facility water quality standards that must
be maintained in effluents from the facility. Generally these standards are based on maximum allowable concentration levels for contaminants of concern. Facilities may have problem meeting these limits, particularly
during stormwater events which increase the levels of pollutants in the discharge stream.
Complications arise since almost all States have a back log of permits awaiting approval.
Future permit requirements may include TMDLs
or Total Maximum Daily Loads on the receiving waters. TMDLs cause shipyards concern since they quantify point and non-point sources of pollutants. Yards are afraid they may be faced with additional burdens beyond those at the
present.
Contact
salter.joel@epa.gov
Karen Keeley, EPA - Bioaccumulation of TBT in State of Washington Coastal Waters
Keeley's group was faced with
determining the level of TBT cleanup to recommend for the Harbor Island Superfund Site in Seattle, Washington. High TBT levels were measured in the West Channel of Harbor Island ranging up to 50 ppm in sediments.
Keeley
first made a review of the literature. She found that although there was an abundance of reports available regarding levels of TBT in tissues or in the water column, very little data is available regarding effects from
TBT. No TBT sediment criteria was available at all.
Keeley decided to identify a "trigger level" of TBT in sediments that would correlate with a corresponding adverse tissue level in target organisms. To do
this, her group performed 'real' data evaluations using marine organisms representative of the area against the sediments of the site. Tests were performed to determine the exact "trigger level" for TBT in sediments
for this superfund site.
After extensive testing Keeley's group calculated a site trigger level value of 3 ppm dry weight TBT. If any sediments in the site exceeded this level, cleanup would be required.
No stations
exceeded the site specific trigger value of 3 ppm dry weight. The EPA's current recommendation is NO ACTION.
Keeley's work is significant because it identifies one of the few instances where the EPA calculated a set value
based on real data and not upon "voodoo" modeling calculations. This refreshing policy change may set the stage for future actions based upon site specific values rather than generic values of little or no
correlation to local environments.
Contact: K. Keeley:
keeley.karen@epa.gov
Michael Champ - Overview of the Science and Regulation of TBT
Champ discussed the history of regulations for tributyltin in the United States. He outlined the reasons for the Organotin Act of 1988 and its consequences. In 1988, TBT biocide was limited to application on hulls of
ships exceeding 25m in length. This step hoped to stop the main input of TBT at marinas.
Recent regulatory events with the International Maritime Organization may force the US to enact a full ban on TBT. Despite
scientific evidence showing reductions in TBT levels, environmental groups are pushing the IMO to enact a worldwide total ban on TBT. It is expected that IMO will suggest a ban on application of TBT by 01/01/03 and a full ban
on presence of TBT on ship hulls by 01/01/06.
Along with the many issues raised, Champ outlined the problems of monitoring such a ban. Even more pressing is the issue of the lack of testing of alternatives to TBT based
paint. Little data is available to shipowners regarding effectiveness, cost and environmental problems. It is very likely that one or more of these alternatives may turn out to be as environmentally harmful as TBT.
Champ argued for the establishment of a Marine Coatings Board. Such a board would make an extensive review of all the alternative antifouling paints available. Tests would include environmental harm, effectiveness, and
many other criteria required by industry and government. Results would be available to everyone.
The Marine Coatings Board could likely save millions of dollars for the shipping industry by recommending the most
effective alternatives for antifouling paints in differing circumstances. It could also avert the possibility of a future environmental disaster resulting from harmful antifouling paints chosen in the rush to find an
alternative to TBT.
Contact M. Champ:
machamp@aol.com
