united states
                                   i i-/a/u/o=tr
&EPA
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         DEVELOPMENT  DOCUMENT
                  FOP
   PROPOSED BEST  MANAGEMENT PRACTICES
                for the
   SHIPBUILDING AND REPAIR INDUSTRY:
                DRYDOCKS
         POINT SOURCE CATEGORY
           Douglas M.  Costle
             Admin istrator
             Swep T.  Davis
     Acting Assistant Administrator
   for Water and Hazardous Materials

           Albert J.  Erickson
 Acting Deputy Assistant Administrator
    for Water Planning and Standards
           Robert B. Schaffer
 Director, Effluent Guidelines Division

             Ernst P. Hall, P.E.
    Chief, Metals & Machinery Branch

         John Penn Whites-carver
            Project Officer
            December, 1979
      Effluent Guidelines Division
Office of Water and Hazardous Materials
  U.S. Environmental Protection Agency
        Washington, D.C.   20460

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                               ABSTRACT


This document presents the findings  of  an  extensive  study  of  the
shipbuilding  and repair industry.  Its purpose is to provide specific
guidance for the development of discharge permits to be  issued  under
the  authority  of  Section «K)2 of the Federal Hater Pollution Control
Act as amended.   These  permits  are  issued  by  state  and  federal
authorities   participating   in   the  National  Pollutant  Discharge
Elimination System (NPDES).

The studies conducted by the  Environmental  Protection  Agency  (EPA)
determined  that  the  imposition  of national industry-wide numerical
limitations and standards is impractical at this time..  This document,
therefore, provides guidance which recommends specific best management
practices.  Such management practices should be tailored  to  specific
facilities.   This  determination  shall in no way restrict the use of
numerical limitations in NPDES permits.

The best management practices identified in  this  document  shall  be
guidance  for the determination of best practicable control technology
currently available, best available  control  technology  economically
achievable,   and  best  available  demonstrated  control  technology.
Supporting data and rationale are contained in this document.
                                  ii

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                          TABLE OF CONTENTS

Section                  Title                            Page

I         CONCLUSIONS                                        1

II        RECOMMENDATIONS                                    5

          BEST MANAGEMENT PRACTICES  (BMP)                    5

III       INDUSTRY CHARACTERIZATION                          9

          BACKGROUND - THE CLEAN WATER ACT                 10

          SUMMARY OF METHODS USED FOR DETERMINING        i  11
          THE PRACTICALITY OF EFFLUENT LIMITATIONS
          GUIDELINES AND STANDARDS OF PERFORMANCE

          GENERAJL DESCRIPTION OF INDUSTRY                  14

IV        INDUSTRY CATEGORIZATION                           39

          INTRODUCTION                                      39

          INDUSTRY SUBCATEGORIZATION                       39

          FACTORS CONSIDERED                                39

V         WATER USE AND WASTE CHARACTERIZATION             41

          INTRODUCTION                                      41

          SPECIFIC WATER USES                               44

          PROCESS WASTE CHARACTERIZATION                   47

          QUANTITATIVE DATA                                 51

VI        SELECTION OF POLLUTION PARAMETERS                 67

          INTRODUCTION     "                                 67

          RATIONALE FOR THE SELECTION OF           .        69
          POLLUTION PARAMETERS

          RATIONALE FOR REJECTION OF                   "78
          POLLUTION PARAMETERS

VII       TREATMENT AND CONTROL TECHNOLOGY                 81
                                  iii

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          INTRODUCTION                                     81

          BEST MANAGEMENT  PRACTICES                        83

          CURRENT TREATMENT  AND CONTROL                    85
          TECHNOLOGIES

          CONTROL AND  TREATMENT OF WASTEWATER              93
          FLOWS

          TREATMENT AND CONTROL TECHNOLOGIES               94
          UNDER DEVELOPMENT  OR NOT IN COMMON
          USE

          NON-WATER QUALITY  ENVIRONMENTAL                  98
          ASPECTS

VIII      COST OF TREATMENT  AND CONTROL                   103
          TECHNOLOGY

          INTRODUCTION                                    103

          IDENTIFICATION OF  METHODOLOGY                   10t
          CURRENTLY USED IN  BEST MANAGEMENT
          PRACTICES

          UNIT COSTS OF BEST MANAGEMENT                   105
          PRACTICES

          COSTS ATTRIBUTED TO  BEST MANAGEMENTx            116
          PRACTICES vs ENVIRONMENTAL  COSTS

IX        ACKNOWLEDGEMENTS                                119

X         REFERENCE AND BIBLIOGRAPHY                       121

          REFERENCES              ,                         121

          BIBLIOGRAPHY                                     123

XI        GLOSSARY      "                                   129
                                  iv

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                           LIST OF FIGURES
Number                    Title                          Page

III-l     Typical Graving Dock                             16
III-2     Typical Transverse Section of a                  19
          Floating Drydock
TII-3     Typical Inside and Outside Water                 21
          Levels for Complete Docking Cycle
          of Floating Drydock
V-l       Major Flows Associated with Drydocked            12
          Vessel

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                            LIST OF TABLES

Number                   Title      .                     page

III-l     Summary of Shipyard Information                  13
          Acquisition Program

III-2     Abrasive Blasting                                24

III-3     Constituents of Abrasive Blast                   27
          Material at Naval Shipyards
III-4     Compositions of Formula Paints                   28

III-5     Compositions of Organotin               ''"'      30
          Antifouling Paints

III-6     Location Factors                                 32

III-7     Utilization of Drydocking Facilities             35

III-8     Graving Dock Lengths and Water Volumes           37

V-l       Water and Wastewater Practices, Shipyards        43
          A through G

V-2       Summary of NDPES Monitoring at                   54
          Shipyard A - August 1975 through
          September 1975

V-3       Summary of Shipyard Test Results of              55
          EPA/Shipyard Monitoring at GD fB-3 at
          Shipyard B - May 1974

V-4       Summary of EPA Testing of EPA/Shipyard           56
          Monitoring of GD fB-3 at Shipyard B -
          May 1974

V-5       Summary of NPDES Monitoring of Drainage          57
          Discharge of Shipyard B - February 1975
          Through February 1976

V-6       Summary of Contractors Monitoring at .      *•    58
          Shipyard B - April 1976

V-7       Summary of All Monitoring at Shipyard B          59
                                  vi

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V-8       Summary of NPDES Monitoring of Drainage          60
          Discharges at Shipyard D - January 1975
          through December 1975

V-9       Summary of Contractor's Monitoring of            61
          GD #D-3 Shipyard D - May 1976

V-10      Summary of All Harbor and Drainage               62
          Discharge Monitoring at Shipyard D

V-ll      Grain-Size Analysis of Unspent Grit              65
          (Sample 1)

V-12      Grain-Size Analysis of Spent Grit                66
          and Spent Paint  (Sample 2)

VI-1      Materials Originating from Drydocks              68
          which May be Discharged to Waterways

VI-2      Parameters Which May Be Present In               69
          Wastewater Discharges From Drydocks

VI-3      Pollution Parameters                             71

VI-U      Parameters Rejected as Pollution                 79
          Parameters

VII-1     Water Quality Treatment and Control              86
          Technologies Currently Being Used In
          Drydocks

VII-2     Water Quality Treatment and Control              87
          Technologies Under Development or Not
          Being Used in Drydocks

VII-3     Reported Application of the Treatment            88
          and Control Technologies

VIII-1    Unit Costs of Selected Operations Which         107
          May Be Used in Best Management Practices

VIII-2    Cost of Disposal of Solid Waste Removed         108
          From Docks  (Includes Hauling and Landfill
          Fees)
                                 Vil

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                              SECTION I

                             CONCLUSIONS


An  engineering  evaluation  of  graving  dock  and  floating  drydock
operations  was  conducted  to  determine  potential for generation of
pollutants   from   shipbuilding   and   repair    operations.     The
practicability  of  establishing  numerical  effluent  guidelines  was
evaluated.  Current techniques employed by  shipyards  were  evaluated
with   respect   to  practices  which  reduce  constituent  levels  in
discharges and with respect to variations in repair  practices  within
the industry.

The conduct of the work involved contacts with thirty-eight shipyards,
engineering  visits  with  data  collection  in  seven  shipyards, and
sampling   during   ship   repair   operations   in   two   shipyards.
Additionally,   prior  work  conducted  by  the  EPA,  discharge  data
collected in  response  to  NPDES  discharge  permit  monitoring,  and
relevant  literature  prepared by the EPA, Navy, and private shipyards
were evaluated.

This  industry  is  such  that  numerical  effluent  limitations   are
impractical  and  difficult  to  apply  in  a  manner  which  could be
monitored; therefore, guidance is provided for controlling  wastewater
pollutant  discharges  which require that best management requirements
be applied.

The quality of the water discharged from drydocks is highly  dependent
upon  the  process used for removal of paint, rust, and marine growths
from the metal surfaces of ship  hulls.   These  materials  are   found
mixed  in the spent blasting material.  Rust and marine growth removed
from the sides of the ship may increase quantities of  solids  in the
waste stream.

Spent  paint  contains  compounds  of  copper, zinc, chromium, tin and
lead, as well as organotin compounds  (References 5,  6,   8,   and  15).
Copper,   Zinc,  chromium,  and  lead   have been identified as priority
pollutants and as such, their discharge must be  subject  to  control.
The paint contributes to the solid load in the waste stream as well as
coming   in  contact  with  stormwater, flooding waters, hosewater, and
water spills.  Additionally, it can be washed, pushed, or blown  into
uncovered drains or  shore waters.

Antifouling   paints  are  of  particular concern.  Toxic  constituents,
such as   copper  or  organotin  compounds   are  used   in  these   paint
formulations.   Of   special  concern  are the new organotin antifouling
paints due to irritant  and toxic  effects of the paint.

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The evaluation of literature, observations,  and  data  leads  to  the
following conclusions:

      1.   Segregation of  water,  except  rainwater,  from  debris  on
          drydock  decks  and  removal  of  debris,  spent  paint  and
          abrasive are the two most  practical  methods  for  reducing
          discharge of solids and wastewater.

      2.   Yards servicing freshwater  vessels  genereilly  do  not  use
          abrasive .blasting  in  preparing  the  hull  for  painting;
          therefore, some recommendations have been identified  to  be
          deleted for yards not using abrasive blasting.

      3.   Existing floating drydocks cannot be  effectively  monitored
          by  normal  sampling  procedures because water drains from a
          rising  dock  through  many  scuppers,  the  ends,   between
          pontoons, and through other openings.

      4.   On the basis of available sampling data, the  type  and  the
          degree  of  activity  occurring  in  the yards do not relate
          consistently to levels of pollutant constituents present  in
          the wastewater.

      5.   Innovations  such  as  closed-cycle  blasting   and   vacuum
          equipment  are  currently  in the development stage and show
          promise for increased productivity,  reduction  in  airborne
          particulates,   improved  working  conditions,  and  reduced
          abrasive blasting debris accumulations in drydocks.

      6.   Clean-up  practices  appear  to  enhance   productivity   by
          improving  working  conditions  and allowing workers greater
          access to work areas.

      7.   Current regulations governing  oil  and  grease  spills  are
          applicable  to  floating drydock and graving dock operations
          during flooding and deflooding.
                                         ' "• ff 1. •r-Tv? ~ "
The above conclusions are based upon data obtained during sampling  at
two facilities and similar data from other sources.  Due to the nature
of  the  facilities,  sampling  techniques are difficult to employ and
estimates of the pollutant load had to take into account the processes
occurring and the material balance.  A complete  material  balance  on
the   abrasive  and  spent  blasting debris was considered and rejected
because  of  inherent  inaccuracies.   Such  factors  as  the  unknown
quantity  of  marine growth present on the hull, the unknown amount of
paint to be removed, and uncontrollable introduction of rainwater  and
leakage   into  the  abrasive  blasting  debris  contribute  to  these
inaccuracies.  Further, dispersion of the material  in  the  dock  and
possible inclusion of other forms of debris (for example, sediment and

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marine organisms which enter during flooding and when the caissons are
open) compound the problems associated with a material balance.

Shipyard  practices  strongly  influence the amount of waste produced.
Yards servicing only freshwater vessels produce no  spent  antifouling
paints   since  antifoulants  are  not  used  on  freshwater  vessels.
Freshwater vessels are rarely subjected to abrasive blasting and  thus
the spent primer paint and abrasive are not produced.            -"-

Shipyards  servicing  commercial oceangoing vessels remove paint, both
antifouling and anticorrosive, to varying  degrees  depending  on  the
desires  of  the  vessel  owner  (Reference  5).   Naval  vessels  are
customarily stripped  of  paint  to  bare  metal,  whereas  commercial
vessels  are  stripped  to  bare  metal  only  occasionally  and  more
frequently only lightly sand blasted to prepare the surface to receive
a coating of paint.  Spent antifouling paint thus occurs in  shipyards
in different quantities.

Graving   docks  are  subject  to  inflows  of  water  which  are  not
encountered with floating drydocks.  Groundwater and gate leakage  are
the two major sources.  Rainfall varies with climate but constitutes a
third  source.   These inflows must be pumped from graving docks while
rainfall can run off floating drydocks.

reachability of spent paint is still an unresolved question.   Primers
containing  lead  oxide  and  zinc  chromate  do  not appear to pose a
leaching problem.  Antifouling paints containing copper oxide  may  be
leachable  under some conditions, but factors such as amount of active
material remaining,  water  pH,  water  temperature,  water  hardness,
particle  size,  and contact time would appear to influence the amount
of leaching if it occurs  (References 5, 16,  17).  Organotin paints may
present hazards to workers during dry abrasive blasting.  These paints
are  relatively new and little experience  has  been  .accumulated  with
them.  Major unknowns with organotin paints are those of the extent of
emission  of  tributyl-tin-oxide or tributyl-tin-fluoride  (toxicants),
the  conversion of the organotin compounds to inorganic tin, and again,
the  actual leachability of the material.  Formulations are prepared in
differing concentrations depending upon the  owners'  specifications and
the  expected life of the protective coating.

Finally, it is concluded that a number  of   management   practices  are
used  at  some yards which can be adapted to the needs of other  yards.
All  facilities practice some degree of  clean  up  at  various  times,
although  this  may consist only of moving debris out of the wort area
when accumulations interfere  with  operations.   During the  docking
period, some  facilities use extensive clean-up procedures.  In general
drydock  clean up is directed toward improving productivity and  safety
and  toward maintaining acceptable working conditions.  Both mechanical

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and manual methods are in use.  Control  of  water  flows  within  the
dock, like clean-up procedures, vary with each facility.

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                              SECTION II

                           RECOMMENDATIONS


Based  on  the  results  of  various  studies,  it  is  concluded that
numerical effluent guidelines should not be established at  this  time
because  the  nature  of  the  discharge is not conducive to numerical
monitoring.

On the  basis  of  practices  observed  in  and  reported  by  various
shipyards.  Best  Management  Practices  (BMP) have been developed for
general application, and should be considered as guidance in  lieu  of
numerical   limitations.    These   are   recommended   for   shipyard
implementation by each individual facility in a manner best suited  to
the  particular needs and conditions prevailing.  The magnitude of the
problem, equipment needed, physical drydock factors, scheduling, etc.,
should be considered in developing a plan to abate pollution.

The following specific requirements shall  be  incorporated  in  NPDES
permits  and  are  to  be  used  as  guidance  in the development of a
specific facility plan.  Pest Management Practices  (BMP)  numbered  2,
5,  7 end 10 should be considered on a case-by-case basis for yards in
which wet blasting to remove paint or dry  abrasive  blasting  do  not
occur, and BMP 10 does not apply to floating drydocks.

     BEST MANAGEMENT PRACTICES (BMP)

BMP 1.    Control of Large Solid Materials.   Scrap  metal,  wood  and
          plastic,  miscellaneous  trash  such  as  paper  and  glass,
          industrial scrap and waste such as insulation, welding rods,
          packaging, etc., shall be removed  from  the  drydock  floor
          prior to flooding or sinking.

BMP 2.    Control of Blasting Debris.  Clean-up  of  spent  paint  and
          abrasive  shall  be  undertaken  as  part  of  the repair or
          production activities to the degree technically feasible  to
          prevent  its entry into drainage systems.  Mechanical clean-
          up  may  be  accomplished  by  mechanical  sweepers,   front
          loaders,  or  innovative  equipment.  Manual methods include
          the use of shovels and brooms.  Innovations  and  procedures
          which improve the effectiveness of clean-up operations shall
          be adapted, where they can be demonstrated as preventing the
          discharge  of  solids.   Those portions of the drydock floor
          which are reasonably accessible shall be  "scraped or broomed
          clean"  (see Glossary) of spent abrasive prior to flooding.

          After a vessel has been removed from  the  drydock  and  the
          dock  has  been  deflooded for repositioning of the keel and

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          bilge blocks, the remaining areas of the  floor  which  were
          previously  inaccessible  shall  be  cleaned  by scraping or
          broom cleaning prior to the introduction of  another  vessel
          into  the  drydock.  The requirement to clean the previously
          inaccessible area shall be waived  either  in  an. emergency
          situations  or when another vessel is ready to be introduced
          into the drydock within fifteen (15) hours.  Where tides are
          not a factor, this time shall be eight (8)  hours.

BMP 3.    oil. Grease, and Fuel Spills.  During the  drydocked  period
          oil, grease, or fuel spills shall be prevented from reaching
          drainage  systems  and  from  discharge with drainage water.
          Cleanup shall be carried out promptly after an oil or grease
          spill is detected.                 •      .

BMP 4.    Paint and Solvent Spills.  Paint and solvent spills shall be
          treated as oil spills and segregated from  discharge  water.
          Spills  shall  be  contained  until  clean-up  is  complete.
          Mixing of paint shall be carried out in locations and  under
          conditions such that spills shall be prevented from entering
          drainage systems and discharging with the drainage water.

BMP 5.    Abrasive Blasting Debris (Graving Docks) .  Abrasive blasting
          debris in graving docks shall be  prevented  from  discharge
          with  drainage  water.   Such blasting debris as deposits in
          drainage  channels  shall  be  removed   promptly   and   as
          completely  as  is  feasible.   In some cases, covers can be
          placed over drainage channels, trenches, and other drains in
          graving docks to prevent entry of abrasive blasting debris.

          The various process wastewater streams shall  be  segregated
          from sanitary wastes.  Gate and hydrostatic leakage may also
          require segregation.

BMP 6.    Segregation of waste Water Flows in Drvdocks.   The  various
          process wastewater streams shall be segregeited from sanitary
          wastes.   Gate  and  hydrostatic  leakage  may  also require
          segregation.

BMP 7.    Contact Between Water and  Debris-   Shipboard  cooling  and
          process  water  shall  be directed so as to minimize contact
          with spent abrasive and paint and other debris.  Contact  of
          spent  abrasive  and paint by water can be reduced by proper
          segregation and control of wastewater streams.  When  debris
          is  present,  hosing  of the dock should be minimized.  When
          hosing is used as  a  removal  method,  appropriate  methods
          should  be incorporated to prevent accumulation of debris in
          drainage systems and to promptly remove it from such systems
          to prevent its discharge with wastewater.

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BMP 8.    Maintenance of Gate Seals and Closure.  Leakage through  the
          gate  shall  be  minimized  by repair and maintenance of the
          sealing  surfaces  and   proper   seating   of   the   gate.
          Appropriate  channelling  of  leakage  water to the drainage
          system should be  accomplished  in  a  manner  that  reduces
          contact with debris.

BMP 9.    Maintenance of_ Hoses,  Soil  Chutesf  and  Piping.  ^Leaking
          connections,  valves, pipes, hoses, and soil chutes carrying
          either water or wastewater shall  be  replaced  or  repaired
          immediately.   Soil chute and hose connections to the vessel
          and to receiving lines or containers shall be  positive  and
          as leak free as practicable.

BMP 10.   Water  Blasting,  Hydroblasting,  and  Water-Cone   Abrasive
          Blasting   (Graving  Docks).   When  water  blasting,  hydro-
          blasting, or water-cone blasting is used in graving docks to
          remove paint from surfaces, the resulting water  and  debris
          shall be collected in a sump or other suitable device.  This
          mixture   then  will  be  either  delivered  to  appropriate
          containers  for  removal  and  disposal  or   subjected   to
          treatment  to concentrate the solids for proper disposal and
          prepare the water for reuse or discharge.

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                             SECTION III

                      INDUSTRY CHARACTERIZATION


Shipbuilding and repair operations have been identified by  EPA  as  a
division  of the ship construction industry requiring consideration of
point  source  discharges  which  may  require   effluent   limitation
guidelines.   Specifically,  graving  docks and floating drydocks were
evaluated with respect to the  potential  contamination  of  receiving
waters  by  wastes  generated  by  ship  repair  and discharged during
flooding of graving docks, immersion of  floating  drydocks,  or  with
drainage water and runoff.

An  engineering  evaluation  .of  graving  dock  and  floating  drydock
operations was conducted to  determine  potential  for  generation  of
wastes from shipbuilding and repair operations in graving and floating
drydocks.    The   practicality  of  establishing  numerical  effluent
limitation guidelines was evaluated for drydocks.  The evaluation  was
accomplished by:

     o    Literature Pesearch

     o    Contacting and visiting shipyards

     o    Observing ship repair operations  and  the  applications  of
          methods   designed   to   reduce  or  eliminate  pollutional
          constituents in effluents

     o    Sampling and analyzing discharge constituents

     o    Determining the feasibility of monitoring  and  sampling  of
          waste discharges from graving docks and floating drydocks

     o    Evaluating the technology being utilized to treat or control
          pollutant  discharges,  and  determining   what   applicable
          technology  may  be  applied  to  minimize  the discharge of
          pollutants to receiving waters

There are eighty-four shipyards in  the  United  States  that  utilize
graving  and  floating  drydocks.  Among the shipyards are sixty-eight
graving docks and 151 floating drydocks.  In the conduct of the  work,
thirty-eight  shipyards  were  contacted  on  the Atlantic Coast, Gulf
Coast,  Great  Lakes  and  Inland  Waterways,  and  Pacific  Coast  to
determine  which  of  the  major  shipyards are involved in minimizing
pollutant discharges by utilizing  specific  control  methods.   Seven
shipyards,  referred  to  in  the  text  by  letters A through G, were
visited to observe operations and record  data.   Samples  were  taken
from  the  discharges  from  graving  docks  of  two  of  these  seven

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shipyards, shipyards B and D.   The  samples  were  analyzed  and  the
constituent  levels  were  evaluated  with  respect to the ship repair
operations being performed and the discharge control methods utilized.
The analyses were combined with other engineering  data  to  establish
the degree of pollutant discharges, to define the nature of .discharges
from  ship  repair  operations,  and  to recommend effluent limitation
guidelines if practicable or alternatives to guidelines if necessary.

BACKGROUND - The Clean Water Act            ^

The Federal Water Pollution Control Act Amendments of 1972 established
a  comprehensive  program  to  "restore  and  maintain  the  chemical,
physical,  and  biological integrity of the Nation*s waters."  Section
101(a).   By  July  •!,  1977,  existing  industrial  dischargers  were
required to achieve "effluent limitations requiring the application of
the  best practicable control technology currently available" ("BPT"),
Section 301 (b) (1) (A); and by July  1,  1983,  these  dischargers  were
required to achieve "effluent limitations requiring the application of
the  best  available technology economically achievable ... which will
result in reasonable further progress  toward  the  national  goal  of
eliminating   the   discharge  of  all  pollutants"  ("BAT"),  Section
301(b)(2)(A).  New industrial  direct  dischargers  were  required  to
comply  with  Section  306  new source performance standards ("NSPS"),
based on best available demonstrated technology; and new and  existing
dischargers  to  publicly owned treatment works  ("POTWs") were subject
to pretreatment standards under Sections 307 (b) and <[c)  of  the  Act.
While  the requirements for direct dischargers were to be incorporated
into National Pollutant Discharge Elimination System   (NPDES)   permits
issued  under Section 102 of the Act, pretreatment standards were made
enforceable  directly   against   dischargers   to   POTWs   (indirect
dischargers) .

Although  Section  402 (a) (1) of the 1972 Act authorized the setting of
requirements for direct dischargers on a case-by-case basis.  Congress
intended  that,  for the most part, control requirements would be based
on regulations promulgated  by  the  Administrator  of  EPA.   Section
304(b) of the Act required the Administrator to promulgate regulations
providing guidelines for effluent limitations setting forth the degree
of  effluent  reduction . attainable through the application of BPT and
EAT.    Moreover,  Sections  304 (c)  and  306  of  the   Act   required
promulgation of regulations for NSPS, and Sections 304(f), 307(b), and
307(c)   required   promulgation   of   regulations  for  pretreatment
standards.  In addition to these regulations for  designated  industry
categories.  Section  307 (a)  of the Act required the Administrator to
promulgate effluent standards applicable to all dischargers  of  toxic
pollutants.   Finally,  Section  501(a)  of  the  Act  authorized  the
Administrator to prescribe any additional  regulations  "necessary  to
carry out his functions" under the Act.
                                 10

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EP\  was  unable  to promulgate many of these regulations by the dates
contained S the Act.  In 1976, EPA was sued by several  environmental
groups",  anS  insettlement  of  this  lawsuit  EPA  and the plaintiffs
Ixecuted a "Settlement Agreement", which was approved  by  the  Court.
This  Agreement  required  EPA  to  develop  a program and adhere to a
scnldulflSr  promulgating  for  21  major  industries  BAT  effluent
flotations   guidelines,   pretreatment  standards,  and  new  source
Performance standards for 65  "priority"  pollutants  and  classes  of
pollutants.   See  Natural Resources Defense council, Inc.. v. Train, »
ERC 2120  (D.D.C. 1976), modified March 9, 1979.

on December 27,  1977, the President signed into law  the  Clean  .Water
Act of 1977.  Although this law makes several *£"*«**££• ££t£S
Federal   water pollution control program, its most significant feature
Is iS  incorporation into the Act of several of the bas ic elements  of
the    Settlement  Agreement  program  for  toxic  pollution  control.
SectionTaoito) (2) (A) and 301 (b) (2) (C) of  the  Act  now require  the
achievement   by  July  1,   1984.  of  effluent  limitations   requiring
application ofBAT for "toxic" pollutants, including the 65 "Priority
pollutants and classes of pollutants which Congress  declared  "toxic"
Snder  Section   307 (a)   of  the  Act.  Likewise, EPA's  programs  for  new
source performance standards  and pretreatment  standards  are now  aimed
principally   at  toxic pollutant  controls.  Moreover, to  strengthen  the
toxics control  program;  Congress added  Section  304 (e)  to  the Act,
authorizing ^Administrator to prescribe "best  management Practices"
1"BM?s")  to prevent the release  of toxic and hazardous pollutants from
plant  site   runoff,  spillage or leaks, sludge or waste disposal,  and
dra?nagf from^aw material  storage associated with,  or  ancillary  to,
the  manufacturing or treatment process.

 In  keeping with its emphasis on toxic pollutants, the Clean Water Act
 of 1977 allo revised thl control  program  for  non-toxic  pollutants.
 instead  of EAT for "conventional" pollutants identified under Section
 304
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 SUMMARY OF METHODS USED FOR DETERMINING THE PRACTICALITY  OF  EFFLUENT
 LIMITATIONS GUIDELINES AND STANDARDS OF PERFORMANCE              "

 The  recommendations and standards of performance proposed herein have
 been developed in the following manner.

 Industry and Waste Load Categorization

 The industry was first studied to determine whether  or  not  separate
 limitations  and  standards  would be required for different divisions
 within the category.  Factors considered included the  nature  of  the
 physical  facilities  involved,  the  types  of  activities performed,
 processes within each activity, and materials used.

 Raw  waste  characteristics  were  then  identified.    This   included
 analyses  of  (1)   the  sources  and volumes of water required in each
 process, (2)  non-process related sources of  wastes  and  wastewaters,
 and (3)  the components potentially present in wastewaters.

 Wastewaters  originating  from the vessel in drydock included sanitary
 wastes and cooling water.  (Sanitary wastes are not  included  in  the
 scope of this document).  Dock originating wastewaters were identified
 as gate and dock leakage, rainfall, water from occasional wet blasting
 operations,  and  water  used  in flooding the 'drydock for docking and
 undocking of the vessels.     •

 The major concern with respect to  potential  pollution  problems  was
 identified  as  spent  paint  and  abrasive  blasting  material.   Hull
 cleaning practices were found to vary within each yard contacted,  and
 the magnitude of this potential problem likewise varies..

 Recommendations   for  reducing  or eliminating potential environmental
 hazards have been based upon information obtained  in  the  course  of
 this   effort,  prior  work  performed  by  other  organizations,  and
 literature available as reference material.

 Treatment and Control Technologies

 The range of control and treatment technologies  within  the  industry
 was  identified. Included were both treatment technology and operating
 practices.    Applicability  and  reliability  of  each  treatment  and
 control  technology  were  investigated,  as was the  required time for
 implementation.    In   addition,   environmental   impacts   of   such
"technologies  upon  other  pollution  problems,  such as air and  solid
 waste, were identified.
                                  12

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Data Ease

                                    sfc-u
            t«     associations.   poblishea   literature,



IS  wa?er pollution control  plans for these facilities were  reviewed.
                      SSS2 SSS^^SS? J
                             .Table III-1
                   SUMMARY OF SHIPYARD INFORMATION
                         ACQUISITION PROGRAM
 Category

 Graving Docks

 East Coast
 Great Lakes
 Gulf Coast
 West Coast

    Total
                 Total in
                 Category No.
                 of Docks (No.
                 of shipyards)
39  (1U)
 8  ( 5)
 3  ( 3)
18  ( 5)
 Floating Drydocks

 East Coast
 Great Lakes
 Gulf Coast
 west Coast

    Total
 68  (27)
 58  (21)
  7  (  3)
 36  (21)
 50  (23)

151  (68)
             Contacted
             No.  of  Docks
            (No.  of  Shipyards)
              Visited
              No. of Docks
             jNo. of shipyards)
15
 8
 0
12
(  6)
(  5)
(  0)
35 (.15)
29 ( 8)
 7 ( 3)
13 (6)
30 (11)

79 (28)
5 (2)
2 (1)
0 (0)
<» (2)
                                     11  (5)
                  3  (1)
                  0  (0)
                  2  (1)
                  *  (2)

                  9  («)
            work   has  been  performed  by  others  in  an  effort   to
          ize and limit discharges  from'shipyard activities.   One such
      y      Hamilton  Standard  Division  of United Technologies, Inc.,
  recommended  clean-up  techniques   rather  than  effluent  limitations
  (Reference 1).
                                  13

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 Other  studies  have been  performed in  an effort  to  facilitate issuance
 of NPDES permits.   The  EPA office   of   Enforcement,   Denver,  Colorado
 conducted studies  of San  Diego and Newport  News  harbors.  On the basis
 of  its findings,  housekeeping measures were  recommended, primarily to
 prevent contact between water  and  spent  abrasive   and  paint  blasted
 from the vessels  (Reference 2).

 Various  leaching   studies  .have been performed to determine whether or
 not spent paint and abrasive are leachable.   Section  V  discusses  the
 results of these studies.   These previous efforts have been considered
 in the  current  work.

 Cost information   was  obtained directly from industry during shipyard
 visits,  from engineering  firms,  equipment  'suppliers,  and  from  the
 literature.   These  costs   have been  used  to develop general capital,
 operating, and  total  costs  for  each   treatment  and  control  method.
 This generalized   cost  data   was used to estimate  the costs of Best
 Management Practices  in Section VIII.

 Selection of Facilities

 From the  total  population of drydocking facilities  thirty-eight  were
 contacted  by  telephone   to   obtain   information  on  practices  and
 operations, seven  were  visited by  project personnel,  and of the latter
 group two were  selected for sampling of wastewater during operations.

 Shipyards contacted by  telephone were  located in all  geographic  areas
 of   the   continental  United  States.    Visits were conducted to yards
 located on the  East,  West,  and  Gulf Coasts, and on  the  Great  Lakes.
 Sampling  was conducted  on the  East and West Coasts.

 GENERAL DESCRIPTION OF  INDUSTRY

 Activities Carried  Out  At Shipyard Facilities

 The   shipbuilding    and  repair  industry  is  engaged  in  building,
 conversion, alteration, and repair of  all types of ships, barges,  and
 lighters.  These activities  encompass  a broad range of functions, such
 as:  erection of structural  steel frameworks and fastening steel plates
 to the framework to form-a  hull; application of paint systems to hull;
 installation  of   a  variety  of mechanical, electrical, and hydraulic
 equipment within the  structure; repair  of damaged vessels; replacement
 of expended or  failed paint  systems; and restoration of malfunctioning
 equipment and systems to operational condition.  Typical of the  trade
 skills  involved   in  this   industry  are:  shipfitters;  metalsmiths;
welders   and  burners;   machinists;    electricians   and   electronic
 technicians;  pipefitters  and  coppersmiths;  carpenters, joiners and
patternmakers;    painters;   riggers    and   laborers;;    blacksmiths;
boilermakers;  and  foundrymen.   Not   all  of  the listed activities.

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functions, or trade skills are utilized at every  facility.   Some  of
the  functions  require placing the ship into drydock, e.g., replacing
underwater paint systems.  Only those facilities providing  drydocking
capabilities are covered in this document.

Graving Dock Description

Graving  docks are constructed with sides and a bottom and with a gate
at the water end.  The bottom is  located  below  the  adjacent  water
surface level with sufficient depth to allow floating of a vessel into
the dock.  Operations consist of positioning keel blocks on the bottom
of  the  dock to match the keel surface of the ship, flooding the dock
by opening valves, opening the gates, positioning the vessel over  the
keel  blocks,  closing  the  gates,  and  pumping the water out of the
graving dock.  During maintenance operations, the graving dock is kept
dry by sump or stripping  pumps  which  remove  fluids  and  water  by
providing  suction  through  drains located at low points in the dock.
After completing operations on the vessel, the dock  is  flooded,  the
gates  are  opened,  and  the  vessel is floated out of the dock.  The
gates to the graving dock are closed and the water is  pumped  out  to
make  preparations  for  receiving  another  vessel,  or, if identical
vessels are being maintained, the next vessel is moved into  the  dock
prior to removing the water.

Graying  docks  are  usually constructed of concrete although they may
occasionally be  of  timber  or  steel  sheetpile  cell  construction.
Figure  III-l  illustrates  typical  cross section and plan views of a
concrete  graving  dock  and  includes  the  designations  of  drydock
features.

The  preferred  method  of  entrance  closure  is by floating caisson.
Other available types of closure are:  miter gates, flap  gates,  set-
in-place  gates,  sliding  caissons  and  rolling  caissons.  Floating
caissons  are  watertight  structures  with  flooding  and  dewatering
systems   for  operation.   For design of hull, floating stability, and
all operational purposes, they are symmetrical both  transversely  and
longitudinally.   Miter  gates  were  probably  the first satisfactory
mechanical gates.  Each closure consists of a  pair  of  gate  leaves,
hinged  at  the dock walls, swinging horizontally so that when closed,
the free  ends meet in fitted contact.  Gates are moved by means  of  a
hawser  to a nearby power capstan.  The sides and bottoms of the gates
bear against seats in the drydock walls and floor.  A flap  gate  is  a
rigid,  one-piece gate hinged at its bottom, and swinging downward and
outward.  It is a compartmented structure with means for  varying  its
bouyancy  for raising and lowering.  Set-in-place gates are in various
forms, and may be built  in one piece or multiple sections.  They are of
beam and  plate construction, with reactions carried to  the walls  by
girders   and  to  the  floor  by  beams-  Sliding caissons  and rolling
caissons  are built-in box shapes, mounted on hardwood sliding surfaces
                                  15

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       CRANE TRACK


       R TRACK
           n
 7    V   ,fj'..\ C7»   I ^
    .. jELECTRlCAL
    Vjj CONDUITS

     U/V.'v
                  COP2N6
                  X~ CHAIN HANDRAIL

                  	CURB

                  — SERVICE GALLERY

                  	PIPE TUNNEL

                    -ALTAR
      V-A*?
       >,:'..'
FLOODING AND/OR

DRAINAGE

CULVERT

            -PILE
             CUTOFF
             WALL
                                               COURSE
                       CROSS SECTION
   HEAD END
E
                       BODY  OF THE OOCK-
                DOCK CHAMBER
                          PLAN
                                                 ENTRANCE END
                                             WNER SEAt«.
                                                     OUTER
                                                     SEAT
                                                     CAISSON
                                                         nu—^
           F.tgure III-l.   Typical Graving  Dock
                                16

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or metal rollers which move them into or out of place.   They  may  be
equipped  with  air  chambers  for  bouyancy  which reduce the work of
moving.

There are three general methods used for admitting water into  graving
docks.   These methods are:  (1) through culverts built into the lower
parts of sidewalls and connected to floor openings spaced along a dock
length, (2) through culverts passing transversely under the floor near
the entrance with openings leading  upward  into  the  floor,  or  (3)
through ducts in an entrance closure caisson.  ,_>?

Graving  docks  have two dewatering systems.  The collector channel, a
wide, deep, grating covered open culvert leading to the  pump  suction
chamber,  handles  the  greater  portion  of  water  pumped out of the
flooded graving  dock.   Installation  of  a  settling  basin  may  be
justified  because  abrasive  materials  harmful  to  pumps  and  pump
fittings may be washed off a  graving  dock  floor  into  the  pumping
system where damage may result.

The  main  dewatering  system  of  a drydock usually includes: (1) the
suction inlet located  within  the  dock  chambers;   (2)  the  suction
passage  and  culvert;  (3)  pump  suction  chamber;  fU) pump suction
bells;(5)  pumps; (6) discharge, check, and gate values;  (7)  discharge
culvert  including  backwash  trash  rack;  and   (8) hinged stop gate.
Where pumping plants are designed to remove water from more  than  one
dock,  additional  sluice  gates  are  required  to permit independent
pumping of the docks.  At least two main dewatering pumps are  usually
required to achieve reasonable dewatering times.

A  secondary  system  collects the last few inches of water blanketing
the graving dock floor.  This system has  sloping  longitudinal  floor
drain  culverts near the sidewalls which lead to collector channels at
pump wells.  The culverts may have rectangular  cross-sectional  areas
of  several square feet.  They are covered by securely anchored strong
gratings.  Drainage and sump pumps, of lesser capacity than  the  main
dewatering  pumps,  are  provided  to  remove  seepage, precipitation,
caisson and valve leakage, and wash water, and to clear the dewatering
pump suction chamber and drainage system.

Ships  in  graving  docks  do  not  ordinarily  fill  all  their   own
requirements  for  mechanical services essential for work, habitation,
comfort, and protection.  Some services, particularly  those  required
for  repairs and cleaning associated with the docking operations, must
be supplied from  dockside  facilities.   Such  services  include  the
delivery  of  steam, compressed air, water, systems for tank cleaning,
and oxygen and acetylene or electricity for welding.  Utility services
are provided to ships in  drydock  by  lines  from  service  galleries
located  around the upper perimeter of the dock.  The drydock also has
a tank cleaning system.  Means must  be  provided  to  keep  a  docked
                                 17

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vessel  far  enough above the floor to permit work on its keel, giving
proper allowance for removal or installation of sonar domes,  rudders,
propellers,  and similar parts.  Blocking arrangements are laid out in
the dock in accordance with  the  docking  plan  for  each  individual
vessel.  Keel blocks are placed under the longitudinal centerline keel
of  the  vessel.  Bilge  or  side  blocks  are  located  according  to
dimensions indicated in the table of offsets on the  vessel*s  docking
plan.  In some cases, block slides are built into the dock itself.  In
addition,    such   supporting   facilities   as   industrial   shops,
transportation facilities, weight and  materials  handling  equipment,
personnel  and  storage  facilities  are  normally  located  in  close
proximity to drydocks.

Floating Drydock Description
                                                                     "t
As implied by its name, a floating drydock floats on  the  water  with
the  bottom  of  the  drydocked  vessel  above the water surface.  The
floating  drydock  is  a  non-self-propelled  mobile  structure.   The
floating  drydock  consists of a platform and associated ballast tanks
used to raise ships above the water  level  for  work  which  requires
exposure  of  the entire hull.  Ballast tanks are flooded and the dock
platform is submerged to a predetermined  level  beneath  the  water's
surface.   A  ship  is  then  moved  over the dock and positioned over
preset keel and bilge blocks on the floor of the dock platform.   This
position is maintained as the ballast tanks are dewatered.  Dewatering
the  ballast tanks lifts the ship and drydock platform floor above the
surface of the water  (Reference 4).

The following discussion of  the  sinking  and  refloating  procedures
along  with  a  schematic  representation of the action is quoted from
Appendix A of Reference 4.

     "Many different types of floating drydocks have  been  developed.
     The   specific   characteristics  of  the  various  types  differ
     considerably as  a  consequence  of  the  different  requirements
     dictated   from  considerations  of  technical,  operational,  or
     strategic nature.  However, the basic general  features  and  the
     related  terminology are, more or less, the same for all types of
     docks.

     •Figure III-2 illustrates the various parts of a typical floating
     drydock.  The nomenclature used in the figure is standard.

     •The lower, horizontal portion of a U-shaped trough  which  forms
     the  dock  structure  is  called  the  pontoon.   The  top of the
     pontoon, the pontoon deck, forms a platform on which are three or
     more rows of blocks  which  support  a  ship  when  docked.   The
     pontoon  constitutes  the  main  platform  for  the  work  to  be
     performed on the docked ship.  In order to increase  the  working
                                 18

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                           FLYING BRIDGE
        KEEL BLOCKS	
    BILGE BLOCKS
  TOP DECK
                                                                    SAFETY
                                                                 COMPARTMENT
OUTRIGGER
                             PONTOON
                                                                   BALLAST
                                                                 COMPARTMENT
                                                      BUOYANCY
                                                      CHAMBER
             FIGURE III-2.  Typical Transverse Section of a  Floating Drydock
                                      19

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platform,  cantilevered extensions, outriggers, are fitted at the
ends of the pontoon deck. The outriggers do not bear any part  of
the shipls weight, but are particularly convenient for setting up
staging around the ends of a long ship.

•Above  the  two  sides  of the pontoon stand the side walls. The
side walls extend vertically to form, with the  pontoon,  the  O-
shape  of  the  dock  trough.   The  top  of  the  side  walls is
sufficiently high as to be afloat when the dock is  submerged  to
receive  the  largest  ship  it  is capable of docking.  The side
walls usually extend to the full length of  the  dock.   The  top
deck  of  each  side  wall  provides  the necesssary equipment and
working space for handling  the  ship*s  docking  lines.   Gantry
cranes  required for handling material travel on tracks along the
length of the top decks.

•Flying bridges are often installed at one or both  ends  of  the
top  decks,  to  provide personnel passage between the top decks.
They consist of hinged cantilever arms, which can be  swung  open
to permit the ship to enter or leave the dock.

•Most of the space contained within the pontoon and side walls is
utilized  as  ballast  tanks.   The  admission of water to or its
removal from these spaces creates the forces that cause the  dock
to  submerge  or  rise.  The remaining space consists of chambers
which keep the dock afloat and their size determines the limit to
which the dock will submerge when all  ballast  tanks  are  full.
Spaces,  termed  buoyancy  chambers in the pontoon and the safety
compartments in  the  wing  walls,  serve  this  purpose.   These
buoyancy  chambers,  not  being  subject to flooding, may also be
utilized to accommodate machinery, equipment, personnel quarters,
mess rooms, workshops, and stowage spaces.

•The larger floating drydocks  are  sectionalized  to  facilitate
movement  overseas  and  to  render them capable of self-docking.
They can transit the Panama Canal.

•One type of  floating  drydock, \ the  closed  basin,  ARD  type,
differs  somewhat  -in  design and operation from the other docks.
The forward end of- the dock is closed by a  structure  resembling
the  bow of a ship; the aft end is opened and closed by operation
of a stern gate.   Lift  forces  are  provided  by  emptying  the
ballast tanks and by emptying the dock basin.

•Figure III-3 shows typical inside and outside water levels for a
complete docking cycle."
                            20

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    DOCK WITHOUT SHIP
                                  DOCK WITH SHIP
^
^ =T^&fc__

ft
   ^iS^'-^--S--J-^-J^gH5g?


    PONTOOH DECK AWABH
   LJ
     DOCK SUBMLKOCO TO
     TO* Or KEEt CLOCKS
   MAXIMUM
                                                     P COM^UCTEUV WATCHBOKNC
     FIGURE III-3. Typical  Inside  and  Outside Hater Levels For Complete
                      Docking  Cycle  of Floating Drydock
                                    21

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Shipyard Practices

This  section is limited to discussion of those operations normally or
most frequently performed in dry3ock with full recognition that almost
the entire range of activities listed in "Activities  Carried  Out  at
Shipyard  Facilities"  above  are  available  and  imay  on occasion be
required.  The basic functions of a drydock are the  construction  and
repair  of  ships  and  the  cleaning, and painting of ships1 bottoms,
propellers, rudders, and the external parts below the water line..

Drydocks provide access to the ship's bottom and utilities services to
shipyard  personnel.   Drydocks  supply   gas,   electricity,   steam,
compressed  air,  fresh  water,  and salt water to the ship in drydock
from lines attached to or embedded in the drydock.  Processes involved
in drydocking include docking, undocking, tank cleaning, abrasive  and
chemical  paint  removal,  painting  and  mechanical repair of various
ships1 parts.  Mechanical repairs of machinery,  welding,  cutting  of
plates,  and  alterations  of  a  ship's structure are other functions
performed in drydock (Reference 5).

Tank cleaning operations remove dirt and sludges from fuel  tanks  and
bilges  on the ship.  Workmen spray detergents, or hot water, into the
emptied tanks by injecting  cleaners  into  the  steam  supply  hoses.
Spent  wash  water  in  the  tanks is pumped by Wheeler (TM)  machines,
which are combination pump and storage tank units, into tank trucks or
barges for subsequent disposal (Reference 5) .

The almost universally preferred method of  preparing  steel  surfaces
for application of a fresh paint system for saltwater immersion is dry
abrasive   blasting.    For   solely   freshwater   immersion,   light
hydroblasting (a water sweep)  may be adequate to remove loose, flaking
or non-adhering paint in preparation for refurbishing paint systems.

With the exception of the closed-cycle blast machines being  currently
being  developed  and  evaluated,  all  blasting presently carried out
within drydocks is done manually.  Three manual blasting  methods  are
used  within  drydocks, and the characteristics of (the debris produced
by each method are markedly different.

Dry abrasive blasting is a process by which the blasting  abrasive  is
conveyed  in  a  medium  of  high  pressure  air, through a nozzle, at
velocities approaching 450 feet per second.   This  type  of  blasting
produces  the  highest relative amount of dust, and resulting residues
are dry.  Dry blasting is used for virtually all  tank  interior  work
and extensively on exterior hull work (Reference 6)«

The  two  other  manual  blasting methods are wet abrasive blasting in
which water replaces air as the propellant and water cone blasting  in
                                 22

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which  a  spray  of  water  surrounds  the air driven abrasive streams
(Reference 7).

orqanotin antifouling paints may produce toxic dust  if  subjected  to
dry  blasting.   Thus,  wet blasting techniques are used when removing
these paints  (Reference 6).  wet or slurry blasting is  also  used  in
cleaning special underwater equipment, such as resin-constructed sonar
domes,  to  protect  them  from  damage  (Reference  8).  Wet Casting
procedures significantly reduce dust occurrence.  A rust inhibitor may
be added to the water or slurry to prevent rusting of surfaces  before
painting.  Rust  inhibitor  solutions  may  vary  but  usually will be
composed of diammonium phosphate and sodium  nitrite  along  with  tne
abrasive grit and water.

An  abrasiveless method of blasting using jets of high pressure water,
hydroblasting, has been demonstrated for  some  purposes.   Generally,
this  will  only remove surface debris and loose or flaking paint.  By
aoing to very high pressures, on the order  of  10,000  psi,  adhering
paint  can   be removed to bare metal.  Hydroblasting is rarely used in
shipyard operations.

Blasting practices were found to vary widely  between facilities.  Many
factors influence this, some of which  are  discussed  later  in  this
section.   Table  III-2   summarizes  the  blasting  practices  used in
shipyards visited during  the conduct of this  study.  Type of  blasting,
frequency of occurrence,  amount of paint removal, and  blasting  medium
are  qualitatively   indicated,  as  are the type and number of docking
facilities.
                                  23

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                             Table III-2

                          ABRASIVE BLASTING
Ship- Facilities Type of Frequency
yard FD GD Blasting
A 3
B 0
C 0
D 2
E . 0
F 0
G 2
1 Dry
5 Dry
2 Dry
Usually
Usually
Rarely
3 Dry, Also Usually
Closed Cycle
1 Dry
2 Dry
0 Dry
Usually
Rarely
Usually
Usual Amount
of
Paint Removal
Usually to
Bare Metal
Depends on
Vessel, Sand
Sweep to
Bare Metal
None
Usually to
Bare Metal
Depends on
Vessel
Only for
Repair Work
Depends on
Vessel , Never
to Bare Metal
Blasting
Medium*
Camel
Black
Black
Beauty
NA
Kleen
Blast
Kleen
Blast
Black
Beauty
Campbell
Black §2
Sand
Blast
*By trade name.
 FD = Floating Drydock, GD = Graving Dock, NA = Not Applicable

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Of the seven facilities visited, none uses wet blasting .routinely  and
only  one  indicated  its  use  on  rare  occasions..   Shipyard F uses
abrasive blasting  only  in  conjunction  with  repair  work  such  as
welding.

There are two techniques in use for dry abrasive blasting.  The first,
generally  known  as  "sand  sweep,"  is frequently used on commercial
vessels to remove marine growth,  fouling  and  delaminating  coatings
only  in  preparation  for  refurbishment or renewal of paint systems.
The second, more frequently used on  naval  vessels,   removes  marine
growth,  fouling,  and all paint down to "white metal" and abrades the
metal substrate to provide a  suitable  surface  for  adherence  of  a
complete fresh coating system.

The  following procedure quoted from Reference 9, describes the entire
cycle of abrasive blasting.  .It applies equally well  to  dry  or  wet
abrasive  blasting  except  for  addition  of water at the appropriate
point in the cycle.  It should be noted that the  full  cycle  is  not
carried  out  at  all  shipyards - e.g., some facilities have the grit
delivered to their site in the hoppers from which it  flows  into  the
pressure pot.

     "Procedure

     o    Abrasive is delivered in large quantities as a free  flowing
          material by covered railway hopper car or dump truck.

     o    Abrasive is transferred from shipping unit to storage  areas
          by  allowing  abrasive  to  flow  from  shipping  unit  onto
          conveyer  belts  that  dump  it  into  forklift  hoppers  or
          directly  into storage bins.  Usually, abrasive storage will
          be covered by a  permanent  structure  or  temporary  covers
           (canvas or plastic tarpaulin).

     o    When abrasive is required, large hoppers, in excess of 6-ton
          capacity, are loaded by scoop  tractor  or  vacuum  loaders.
          When  full, these hoppers are transferred to the job site by
          forklift truck.

     o    Abrasive from these hoppers is transferred into the pressure
          pots, usually by -gravity feed.

     o    Finally, the abrasive is propelled from the sandblast nozzle
          by compressed air to forcibly impinge on the  surface  being
          cleaned.

     o    Spent abrasive,  paint  particles,  fouling  organisms,  and
          other debris fall to the drydock floor.
                                 25

-------
     o    The debris from the sandblast operations  is  picked  up  by
          scoop  tractors,  hand  shovels,  and/or  other  method  for
          transfer to hoppers or skip boxes..

     o    In some shipyards, spent metallic abrasive is reclaimed  and
          reused,  but abrasive contaminated with antifouling paint is
          discarded in designated landfill areas."

The abrasive may be either metallic or nonmetallic.   Practically  all
blasting  is  done with certain by-product mineral abrasives which are
low in free silica content.  The specification (Reference 10)  used  by
naval  shipyards  purchasing  grit  allows a maximum of 5 percent free
silica  content.   The  constituents  of  abrasive   blast   materials
currently  in  use  by  O.S. Naval Shipyards are shown in Table III-3.
Rationales of naval  shipyards  for  purchasing  particular  abrasives
include:   low   free   silica  content;  less  dusting;  performance;
availability; and price (Reference 8).  Commercial facilities use  the
same or similar materials for like reasons.

Ships  in  drydock  may  be painted internally, on the hull and on the
superstructure.  Because the painting of the superstructure  does  not
require  a  dry  hull  and because drydock availability is limited and
expensive, superstructures are frequently painted while the ship is at
berth or at sea.  The bulk of painting activity in a drydock is  on  a
ship*s hull and internal fuel and water tanks.  Anchor chains, anchors
and  portable ships1 machinery are frequently placed on wooden pallets
in the drydock for painting. Paints  applied  to  protect  metal  from
corrosion  or fouling are sprayed onto most surfaces although painting
of irregularly shaped objects such as chains  is  sometimes  performed
with  brushes.   Occasionally  paints  are  applied  to flat or gently
curving surfaces by roller.

There are two kinds of paint spraying equipment in  use.  One  uses  a
stream of compressed air to convey the paint from container to surface
being  painted.   A  newer  method  rapidly  increasing in use employs
hydrostatic pressure to convey the paint.  It is claimed that  airless
paint spraying is more efficient because of very low paint loss due to
drift  or  overspray.   Almost  all  of  the  paint  is applied to the
intended surface.  Estimates of  losses  due  to  drips,  spills,  and
overspray range from 1 .to 2% for airless paint spraying.  Observations
during  shipyard  visits  of spills while mixing, noticeable overspray
from airguns, and concentrations of droplets on the surface  of  water
running  through  drainage  gutters  generates  more confidence in the
higher than in the  lower   figure.   Occasionally,  flowing  water  is
purposefully used to carry spilled paint into drainage gutters.

Anticorrosive  and  antifouling  paints are typically used on ships in
drydocks.  To these paints may be added  differing  pigment  materials
such  as  lampblack,  red iron oxide, or titanium dioxide to achieve  a
                                  26

-------
          Table II1-3.  CONSTITUENTS OF ABRASIVE BLAST MATERIAL
                            AT NAVAL SHIPYARDS
                           CONSTITUENTS S BY WEIGHT (SEE KO?E)
FACILITY
ABRASIVES
PORTSMOUTH
BLACK DIAMONC
PHILADELPHIA
POLYGRIT
NORFOLK
BLACK BEAUTY
CHARLESTON
SAF-T-BLAST
LONG BEACH
KLEEN BLAST
'.ARE ISLAND
5REEN DIAMOND
PUGET SOUND
BLACK DIAMOND
ROCK-WOOL
SLAG
PEARL HARBOR
3LACK DIAMOND
JAM
SP.EEN DIAMOND
. 	 — —
0
X
o
3
28
42
35
28
19
23
17
16
19

UJ
o
X
o
o
£
6.14
12
4

19
.6
22
26
19
.6
POSTASSIUM OXIOE |

.03
2



.7
2


ALUMINUM OXIOE |
21
11
23
21
9
1
9
9
9
1
MAGNESIUM OXIDE |
1.1
2
1

2.9
23
3
3
3

UJ
o
i
§
i

i
i


.05
.2
1

.05
COMBINED
\ Mil inn ntnvtnr
43
17
34
50
48
52
36
39
48
5?
S
CL.
a.
o

.7


.1

.6
.2
.1

Ul
o
i
o
.f

1



.04
.5
.5

.04
TITANIUM
.95


1





MANGANESE
.04



.22


.22

UJ
o
X
O

13




12
4


5
UJ
UJ
ee
u-





3



u.
_J
.15




01


01
g
.17








NOTE:  Totals may not equal  100 due to rounding  off.   Since  percentages vary
       between lots, these values are approximations  of the  average.
                                    27

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                            Table III-4.  COMPOSITIONS OF FORMULA PAINTS
Formula No.

    117
Anti-corrosion
Mil. Spec. No.


Mil.P-15328
    119
Anti-corrosion
Mil.P-15929
    121
Anti-fouling
Mil.P-15931
     129
Anti-fouling
MiliP-16189
     1530
     1B29
     1B27
     150
     151
     152
     153

     154
     155
 Anti-corros ive
     1020A
 Anti-fouling
 Mil.P-24441
     Composition         lb/100 gal
Polyvinyl-butyral resin
Zinc chroraate
Magnesium silicate
Lampblack
Butyl alcohol
Ethyl alcohoU
Phosphoric acid
Water
Rod Lead
Vinyl resin
 vinyl chloride
 vinyl alcohol
 vinyl acetate
Tricresyl Phosphate
Methyl Isobutyl Ketone
Toluene
Cuprous oxide
Rosin
Vinyl resin
Tricresyl phosphate
Methyl Isobutyl Ketone
Xylene
Anti-settling agent
Cuprous oxide
Lampblack
Rosin
Vinyl  resin
Tricresyl phosphate
Methyl Isobutyl Ketone
Xylene
Antisettling agency

Thixatrope
Polyanide
Polyamide adduct
Magnesium silicate
Titanium dioxide
Butyl  alcohol
Copper phthalocyanine
   blue
Yellow iron oxide
Red iron oxide
Epoxy  resin
Naptha
Diatomaceous  silica
Lampblack
                    Vinyl resin
                    -bis  {Tributyltin) oxide
                    Tributyltin fluoride
                    Carbon black
                    Titanium dioxide
                    Ethylene glycol mono-
                       ethyl  ether  acetate
                    Normal prepanol
                    Normal butyl acetate
gal/100 gal
56
54
8
0.
125
482
28
25
220
145
15
295
295
1440
215
55
50
165
115
5 to
1120
70
185
45
40
200
130
5 to
10 to
20
280 to
250 to
5 to
253 to
0 to
0 to
0 to
SOD to
215 to
0 to
0 to
Ib
161
38
167
19
7
28
102
400



6















9







9
20

320
600
600
304
1
500
300
586
258
150
. 18


.3

.4
.2



6.10
1.59
0.35
0.04
18/40
70.70
2.0
3.0
2.9
12.8
1.5
43.8
40.0
27.40
23.07
4.69
4.92
23.88
15.42
0.62
21.62
4.50
19.83
3.84
3.93
28.92
17.42
0.64














16.1
4.0
16.1
1.3
0.2
3.4
15.1
54.8
                                            28

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particular decorative or camouflage effect.  Table III-U presents  the
chemical composition of the most commonly used external hull paints on
navy ships.

The  anticorrosive paints are either vinyl or vinyl and lead based, or
are of the newer epoxy type which is slowly supplanting the vinyl  and
vinyl-lead paints.  Substantial quantities of both types of paints are
being  used  in  shipyards,  with  some  epoxy paints of unknown exact
compositions   being   supplied   by    manufacturers    but    having
characteristics  essentially  similar  to  the  Navy standard formula.
Both types of paints will be removed by abrasive cleaning methods.

Antifouling paints are designed to prevent growth  and  attachment  of
marine  organisms  on hulls of ships by releasing minute quantities of
toxic substances in  the  immediate  vicinity  of.  the  hull  surface.
Copper-based  paints  using  cuprous  oxide have been the standard for
many years (Reference 5).  The use of organotin paints is very recent,
but growing.   Tributyl tir. fluoride  (TBTF)  and  tributyl  tin  oxide
(TBTO)   are  the  principal  toxicants.   Table  III-5 identifies some
organotin antifouling paints commercially available.
                                 29

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   Identification
M.I. Formula 1020A
Devran MD-3198
Amercoat  1795
Tarset 305
Andrew Brown Colortox
(Brolite  Z-Spar)
M.I. Formula 1010
M.I. Formula 1028
Eiomet
M.I. Formula 1011
Devoe XM-075
P.ustban VY-5529
Glidden No-Cop AF
        Table III-5
      COMPOSITIONS OF
ORGANOTIN ANTIFOULING PAINTS
             Contents
     Vinyl/TBTO/TBTF
     Vinyl/TBTF
     Vinyl/TBTO
     Coal tar epoxy/TBTA
     Vinyl/TBTF

     Vinyl/TBTO/10,10»-oxybis-
     phehoxarsine
     Vin y1/ros in/TETF/Cu 2O
     Vinyl/TBTF
     Vinyl/TBT neodecanate/TBTF
     Epoxy/Cu2O/TBTO
     Vinyl/TBTF
     Vinyl/TBTO
International Tri-lux 40  Vinyl/TBTF
(wide spectrum AF, Mark I)
International Tri-lux 68   Vinyl/TBTF
(wide spectrum AF, Mark II)
Note:  TBTO = Tributyl- Tin Oxide
       TBTF = Tributyl Tin Fluoride
          Reference 11
                                 30

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The  industrial  operations  carried  out  in   drydocks   result   in
considerable  amounts  of  debris  collecting on the dock floor.  This
debris consists of:

     o    Marine  organisms  removed  from  the  hull  by  washing  or
          blasting

     o    Spent grit from abrasive blasting (whether wet or dry)

     o    Old paint particles, flakes, and chips abraded from the hull

     o    Rust particles and flakes abraded from the hull

     o    Fresh paint dripped, spilled, or oversprayed onto the  other
          debris   during  application  to  the  hull,  machinery,  or
          equipment.

These materials have constituents that  are  potential  pollutants  to
adjacent  navigable  waters.   In addition to the pollution potential,
the debris is a hindrance to  further  industrial  operations  in  the
drydock,  a  wear  hazard  to  dewatering and drainage pumps, a weight
addition to floating drydocks,  and an  inconvenience  to  people  who
must  work  in the dock.  All shipyards clean up and remove the debris
but  there  is  wide  variation  in  the  frequency,  technique,   and
thoroughness.

In  addition  to  ship repair and maintenance practices, other factors
can affect the kind and amount of wastes generated in drydock.  During
the conduct of this study it was  established, that  wide  differences
exist  between  practices at shipyards and between conditions existing
at each  yard.   These  differences  also  influence  the  waste  load
generated.   Among  the  factors  noted  as  having impacts upon waste
generation are:

     o    Location - fresh vs. saltwater

     o    Type of ships serviced

     o    Extent of utilization and time of stay in dock

     o    Type of facility* configuration, and age

     o    Clean-up practices                    -,v^-

Table III-6 summarizes, for facilities visited,  factors  relevant  to
the drydock location which bear upon the quantity and type of waste.
                                 31

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Ship-
yard
 A
 B

 C
 D
 E
  G
 Location
East Coast
East Coast
                             Table III-6
                           LOCATION FACTORS
Type of
Water at
Facility  Climate
Brackish  Moderate
Salt      Moderate
Predominant
Vessel
Service
Ocean
Ocean
West Coast   Salt
West Coast   Salt
West Coast   Salt

Great Lakes  Fresh
Gulf Coast   Fresh
          Moderate   Ocean
          Very Dry   Ocean
          Very Dry   ocean
                               Moderate
                               Wet
                      Inland
                      Inland
                      & Ocean
Predominant
Type of
Vessel	
Commercial
Commercial
& Naval
Commercial
Naval
Naval  &
Commercial
Commercial
Commercial
                                   32

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The  facilities  located  in the Great Lakes and Gulf Coast areas were
both on river sites.  The Great Lakes  yard,  however,  services  only
inland waterways vessels while the Gulf Coast yard services both ocean
and  inland  vessels.   All  other  yards  which  were visited service
predominantly oceangoing vessels.  Also shown in Table III-6  are  the
ownership,  commercial, or naval, of the ships predominantly serviced.
The two factors, ocean vs. inland, and naval vs.  commercial,  have  a
major influence on the operations in the dock and the wastes produced.
Oceangoing   vessels   generally   require  antifouling  paints  while
freshwater vessels as a rule do not.   Thus,  antifouling  paints  are
removed  from oceangoing vessels when repainting is needed.  This does
not occur in strictly freshwater operations.

The seven facilities visited included two on the West Coast, three  on
the East Coast, one on the Gulf, and one on the Great Lakes.  Of these
sever.,  two  facilities  had  freshwater  locations,  four  had  ocean
locations, and one was located on an  internal  body  of  water.   Two
facilities  were  naval and the balance were commercial-  Finally, the
age and condition ranged from over fifty years and poor  to  one  year
and excellent.

Naval  vessels  enter  drydock  for extensive maintenance.  During the
course of this maintenance, the antifouling and  anticorrosive  paints
are  removed  to  bare  metal.  Extensive paint removal is not usually
practiced on commercial vessels.  In  general,  freshwater  commercial
ships may receive no blasting prior to repainting, while naval vessels
are  completely  refurbished from bare metal.  Thus, larger quantities
of spent paint and abrasive usually result from work on naval  vessels
than from commercial ships.

A  number of other factors act to create differences in drydocking and
service practices between naval and  commercial  vess-els.   Commercial
vessels   customarily   are   drydocked  annually  or  biennially  for
inspection.   During  these  drydockings,  hull  repainting   may   be
undertaken;  however,  due  to  the  short period between drydockings,
paint deterioration may not be severe and fouling may  be  minimal  or
moderate.  In addition, commercial vessels are usually on the move and
this reduces the amount of fouling which can occur.  Naval vessels are
drydocked on a routine basis at intervals of up to five years or more.
Hull  preparation  and painting must be designed to provide protection
for that period, thus cleaning to bare metal and  the  use  of  higher
levels  of toxicants in antifouling paints than for commercial vessels
is customary.  Since naval vessels spend  much  time  in  port  or  at
anchor,  the  potential   for  fouling is more severe than if they were
underway.

Utilization of the   drydocking   facilities  is  another  factor  which
influences  the  total  waste  generated.   Yards  contacted indicated
utilizations ranging from 30 percent to 100 percent. A  drydock  which
                                  33

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is  used  infrequently or intermittently has less total discharge than
one  operating  on  short  turnaround  service  at  a  high  rate   of
utilization.    Facilities  used  for  new  construction  usually  are
occupied by the activity for periods in excess of  a  year.   In  this
case, not only is the nature of the operation less productive of waste
(no  spent  paint  to  blast off the hull) but flooding occurs only at
launch, once per ship.  Table III-7 summarizes drydock utilization for
yards contacted and visited.

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                             Table II1-7

                 UTILIZATION OF DRYDOCKING FACILITIES

                       	Percent Utilization*	
                        0-30   31-50   51-70   71-90   >90

Facilities Visited

 Graving Docks            2       0       2       2      2
 Floating Drydocks        0       0       3       52

Facilities Contacted

 Graving Docks            2       7       2       5      U
 Floating Drydocks        6      13       6      20      1
 Building Basins2                                        2

Totals

 Graving Docks            4       7       H       7      6
 Floating Drydocks       _£      H      _£      25     _3

    TOTAL                10      20      13      32      9
»Information not available: Graving Docks, 8;
                            Floating Drydocks, 20.
«Not included in totals.
                                  35

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Geographic factors can have  a  major  influence  on  wastewater  from
drydocking  facilities,  especially  from  graving  docks.   Facilities
located in regions  of  low  rainfall  do  not  have  the  problem  of
rainwater  wetting the dock floor.  This is true for both floating and
graving docks.  Thus, in those regions spent paint  and  abrasive  can
usually  be  removed  dry.   Graving  docks  are frequently subject to
groundwater flows into the dock basin.  This problem can  be  critical
in some docks, while for others, it does not exist.  Unless provisions
are  made  to confine and remove rainfall and groundwater (hydrostatic
relief water), waste may be carried from the dock with the  dewatering
flows.

The  age and type of construction of the drydock can have an effect on
the control of waste.  Older docks, both floating and graving, tend to
be constructed with raised slides for bilge blocks.  These  produce  a
series  of wide channels, usually six to ten feet wide, extending from
the dock center line to the  side.   Debris  from  work  in  the  dock
collects  in  these  channels  and  cannot  easily  be removed.  Newer
construction has favored flat  dock  surfaces,  with  keel  and  bilge
blocks  being moved by cranes.  Debris can be more easily removed from
docks of this construction.  Facility size varies  considerably.   For
graving  docks  this  influences the volume of harbor water introduced
during flooding and subsequently removed during dewatering.   Floating
drydocks,  during  sinking  and  refloating, are exposed to the normal
flow of the body of water  in  which  they  are  located,  and  actual
contact  of  water with the floating dock may be many times the volume
of water needed to flood a similarly sized graving dock.  Table  III-8
lists dock sizes and approximate volume  (without vessel occupancy) for
graving facilities contacted during this study.
                                 36

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                             Table II1-8

                GRAVING DOCK LENGTHS AND WATER VOLUMES
Length of Dock, Meters, (Feet) Approximate Dock
Volume, No Vessel,
<122 122-183 183-244 244-305 >305 Million Cubic Liters,
f<4'001 (400-600) (600-800) (800-1000) O1000) million Gallons)
X 3.8
X 13.2
X 13.2
X 20.4
X 21.2
X 21.6
X 23.8
X 26.9
X 27.3
X 28.0
X 28.4
X 32.9
X 34.1
X 39.0
X 42.2
X 57.2
X 57.2
X 58.3
X 59.8
X 70,8
X 73.4
X 73.8
X 79.9
X 92.2
X 111.3
X 143.8
X 173.4
X 177.1
X 190.4
X 213.1
X 244.1
X 244.9
(1-0)
(3.5)
(3.5)
(5,4)
(5.6)
(5.7)
(6.3)
(7.1)
(7.2)
(7.4)
(7.5)
(8.7)
(9.0)
(10.3)
(11-2)
(15.1)
(15.1)
(15.4)
(15.8)
(18.7)
(19.4)
(19.5)
(21.1)
(24.1)
(29.4)
(38.0)
(45.8)
(46.8)
(50.3)
(56.3)
(64. 5)
(64.7)
Totals:
   1
11
8
                                  37

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                              SECTION IV

                       INDUSTRY CATEGORIZATION


INTRODUCTION

In  the development of effluent limitations guidelines and recommended
standards of performance for new sources in  shipbuilding  and  repair
drydocking  operations,  consideration  should be given to whether the
industry can be treated as a whole in the establishment of uniform and
equitable guidelines  or  whether  there  are  sufficient  differences
within  the  industry to justify its division into subcategories.  For
the shipbuilding and  repair  industry,  the  following  factors  were
considered  as  possible justification for industry subcategorization:
dockside and shipboard activities, facility age, salt  vs.  freshwater
facilities,  climate,  and types of dock.  After review, only salt vs.
freshwater, and type of dock  (graving docks and floating drydock) were
found to have distinguishable characteristics.

INDUSTRY SUBCATEGORIZATION

Although there exist  distinguishing  characteristics,  this  document
will  apply  to  all  types  of docks with consideration given to site
specific  differences.   Quantitative  effluent  guidelines,  however,
cannot  be established at this time for drydocks because the nature of
the discharge is not conducive to numerical monitoring.

There are such a wide range of  dockside  activities,  nearly  all  of
which  are  carried  on to some degree in all shipyards, that dockside
activities are not an acceptable criterion for subcategorization.

FACTORS CONSIDERED

Salt vs. Freshwater

Freshwater yards perform very little abrasive blasting  compared  with
shipyards  servicing  saltwater vessels.  Also, antifouling paints are
rot applied to freshwater ships.  Since blasting is  less  common  and
usually  on  a  much smaller scale, and the spent paint composition is
different, shipyards  servicing  only  freshwater  vessels  and  those
performing  neither  wet  blasting  to  remove  paint nor dry abrasive
blasting  should  receive  consideration   with   respect   to   their
difference.  Best Management Practices  (See Section II) numbered 2, 5,
7  and  10  do  not  apply for facilities where wet blasting to remove
paint or abrasive blasting does not occur.
                                  39

-------
Others

All other factors were rejected as bases for subcategorization.  Since
the major source of potential water pollution appears to  result  from
blasting,  the  type  of  shipyard activities also was eliminated as a
possible subcategory.  Age of the facility does  not  directly  affect
the   degree   or  composition  of  discharge.   Because  rainfall  is
unpredictaole and occurs to some extent at all yards, climate also was
rejected as a basis for subcategorization.

The  type  of  dock,  graving  dock  or  floating  drydock,  also  was
considered   and  rejected  as  a  subcategory.   The  same  kinds  of
activities are undertaken in both types of docks  and  thus  the  same
kinds  of  debris and discharges are produced.  The only difference is
that during flooding and deflooding, the water passes over the ends of
and through scuppers along the sides of  floating  drydocks  while  it
flows through one (or more) collector channels in graving docks and is
discharged using pumps.

-------
                              SECTION V

                 WATEP USE AND WASTE CHARACTERIZATION


INTRODUCTION

This  section  describes  the  sources  and uses of water by ships and
industrial operations in  drydocks.   Potable  water  for  use  within
drydocks  is  drawn from the same source that supports the rest of the
shipyard, almost invariably the  contiguous  municipal  system.   Non-
potable  water  is  most  freouently  drawn directly from the adjacent
navigable waterway.                                   .

Water requirements in a drydocking facility can be broadly  classified
as those necessary for the ship and those associated with the drydock.
The  former  include  potable  water,  cooling  water,  water for fire
control, and other shipboard uses of water.  All but potable water are
usually supplied from harbor water.  Drydock  water  uses  are  harbor
water for flooding, hosedown of ship and dock surfaces, occasional wet
blasting  water,  and  dust  scrubber water.  Potable water is used in
drydocks for tank cleaning operations.

Wastewaters similarly originate from both ship  and  drydock  sources.
Ship  wastewater  includes  cooling  water  discharge,  tank  cleaning
wastes, and occasionally boiler water  discards.   Drydock  wastewater
includes  deflooding water, hydrostatic pressure relief water and gate
leakage, rainwater, water use'l in hosedown, tank cleaning water, water
from wet blasting if practiced, and any  water  entering  the  drydock
from the ship or other sources.

Figure  V-l  is  a  schematic  of water and wastewater flows between a
drydock, the drydocked ship,  the  drydock  floor  or  deck,  and  the
harbor.   The  figure represents a graving dock; however, if the flows
indicated by asterisks are deleted,  it  also  represents  a  floating
drydock.

Not all flows are present in all drydocks.  For example, potable water
is  supplied  to  vessels - only  if  crews  are on board.  Hydrostatic
pressure relief water  is  encountered  in  vast  quantities  in  some
graving docks, others are completely free of this stream.

In  addition to water and wastewater flows. Figure V-l shows materials
entering the drydock as a result of  the  repair  activities  and  the
disposition of waste materials resulting from repair activities.

Table V-l summarizes the observations made during the shipyard visits.
The numbered streams in Figure V-l are identified as to their presence
or absence at each of yards A through F in Table V-l.
                                  41

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s:
                                    u
                                    e
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      TT
                               S

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in

o
t.
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                     k
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                     k.

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                                     m
Table V-1.   WATER AND WASTEWATER PRACTICES, SHIPYARDS
                     A THROUGH G
                            • t
          Water and Wastewater Flow Streams<»>
                 In Shipyard Visited
Stream
Number            A     B
Water Into Dock

     1             P     P
     2             P  •   P
     3             P  '   P
     4             P     P
     5             P     P
     6             A     I
     7             P     P
     8             P     T>

Materials Into Dock

     9             II
    10             P     P
    1.1             P     P

Waste Materials to Disposal
    12
    13
           I
           I
           P
Wastewater to Harbor
15
16
17
18
19
20
P
P
P
P
P
A
I
I
P
                         P
                         P
                         P
                         P
                         P
                         I-
                       SHIPYARD
                      C     D
                       P
                       P
                       P
                       I
                      NA
                       A
                      NA
                       P
                       I
                       P
                       P
P
I
P
                       P
                      NA
                       I
                      NA
                       P
                       A
            P
            P
            P
            I
            P
            I
            P
            P
            I
            P
            P
P
I
P
            P
            P
            I
            P
            P
            I
            P
            P
            P
            I
            P
            I
            A
            P
            I
            P
            P
I
I
P
            P
            I
            I
            P
            P
            I
            A
            A
            P
            P
            A
            I
            I
            P
            I
            P
            I
I
I
I
            A
            I
            I
            A
            P
            I
            A
            A
            P
            P
           NA
            A
           NA
            P
            I
            P
            P
I
I
P
            A
           NA
            P
           NA
            P
            A
P - Present, A-Absent, I-Intermittent, NA-Not Applicable  to
    Floating Drydock
 (1) Refer to Figure V-1 for Stream Designation
                                  U3

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SPECIFIC WATER OSES

Water For On Board Ship Use

Once  they  have been placed in service, ships are equivalent to small
towns with respect to their demand for water . and  the  generation  of
wastewater discharges.  The following subsections describe the source,
use,  and  discharge  of  water for each of the several systems aboard
ship.

Potable Water.  Potable water is drawn from supporting facilities when
in drydock.   In  addition  to  direct  consumption  by  the  resident
population, it is used for food preparation and personal hygiene.  The
wastes from these uses become sanitary discharges which are covered by
other regulations and will not be further considered in this document,
except that they should be segregated from process wastewaters.

Fire Protection Water.  While underway, fire protection water is drawn
into  the  vessel from water being sailed upon.  It is pressurized for
use in the fire protection system.  When in  drydock,  the  supporting
facility  provides  non-potable  pressurized  water  for this purpose.
These facilities are sometimes  used  to  hose  down  the  dock  after
dewatering or to help accumulate residual spent abrasive into piles.

Boiler  Feed  Water.   Boiler  feed  water  is  either  distilled from
seawater or drawn from supporting facilities such as  drydocks.   This
type  of  water  is often required to be purer than potable water.  In
use, it is converted to steam in the boiler.  The steam is  then  used
to  drive propulsion, electric generation, and other machinery as well
as for heating purposes.  Finally, the spent steam is  condensed  into
water  and  fed  back into the boiler to begin the cycle again.  Since
this is a closed cycle system there are not  normally  any  discharges
other   than   unintended  leaks.   A  ship  entering  a  drydock  for
maintenance and repair may occasionally have work done on  the  boiler
while  in drydock, and it may be necessary to drain the water from the
boiler.

Cooling Water.  Most of the water supplied to a ship  in  drydock  for
cooling  is  non-potatle  water.  Freshwater cooled equipment normally
uses a recirculating chilled water system in  which  little  water  is
wasted.   Cooling  water  is  used as a flow through heat sink for air
conditioners and various pieces of machinery and electronic equipment.
Waste cooling water is discharged from the ship.into  the  drydock  in
essentially  the  same  condition  as  supplied except for temperature
elevation  (References 5 S 11).

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Water For Industrial Use

Very little  industrial  wastewater  is  generated  by  the  processes
carried  out  in  drydocks.   However, large amounts of water may pass
through the dock basin.  Almost none of the drydocks  in  current  use
have  design  provisions  for the segregation of contaminated and non-
contaminated flows nor do they ensure  isolation  of  non-contaminated
flows   with  regard  to  possible  contamination  from  contact  with
industrial process debris.  This section will list  and  describe  the
source   of   all  waters,  except  shipboard  wastes,  which  can  be
potentially contaminated by flow through the drydock basin.

Launch Water, Graving Docks.  As  described  earlier  a  graving  dock
basin  is ordinarily flooded and dewatered twice.for each ship docked.
Water is admitted from the adjacent  navigable  waterway  through  the
flooding  culverts  or through the caisson gate.  The gate is removed,
the ship is brought into  or  removed  from  the  dock,  the  gate  is
replaced,  and  the  water  is returned to its source by pumping.  The
quality of the water on return, relative to the source,  is  dependent
upon - the  condition of the admitted water and upon any material which
may be added to or removed from it while in the drydock.

Launch Water, Floating Drydocks.  There are two water  flows  involved
in the sinking and raising of a floating drydock.  Sinking and raising
ordinarily happens twice for each ship docked.

The   first   water  flow  is  that  water  admitted  to  the  ballast
compartments from the adjacent navigable water body to sink the  dock.
After  the  ship  is  brought  into or removed from the dock, water is
pumped from the ballast compartments back to the source body,  without
further  contamination,  to raise the dock.  The return flow may be of
better quality than the source since the ballast compartment may serve
as a settling tank.

The second water flow is source body water flowing  through  the  open
ends  of  the U-shaped trough of the dock and over the pontoon deck as
the dock is sunk.  As the dock is raised, water flows out through  the
ends and other openings of the drydock and returns to the source body.
The  quality  of the return flow, relative to the source, is dependent
upon the amount and type of.debris that is present on  the  side  wall
and pontoon deck surfaces prior to sinking as well as upon the time of
exposure and rate of runoff during dewatering.

Wash  Down.   When  a  graving  dock  is flooded, it simulates a large
settling tank.  Silt and mud which enter the dock  with  the  flooding
water deposit on the floor following dewatering.  Marine organisms may
be  trapped  inside  the  dock  basin when the caisson is replaced for
dewatering.  If the dock is not cleaned  after  dewatering,  the  dead
marine  organisms  begin  to  decay  and the silt and mud becomes very

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difficult to  remove (Reference 11).  In those facilities where  these
problems  occur,  the  drydock floor and other surfaces are hosed with
water from the pressurized  non-potable  system.   Existing  practices
generally  may  include  hosing   (1)  after initial dewatering and (2)
prior to final flooding.  These practices were observed in two of  the
seven  shipyards  visited. .  There  are  other  times  of intermittent
hosing.  For instance, water from drydock and  ship  hosing  generates
liquid  industrial  waste and, in addition, may convey solid wastes to
the drainage tunnel for direct discharge to the receiving waterbody.

Washdown also  occurs  occasionally  after  clean  up.   Solid  wastes
remaining  after mechanical and manual clean up efforts may be flushed
by hosing into the drainage tunnel or mixed with  flooding  waters  on
the dock floor during the undocking cycle (Reference 6).
                                         • .  :»:,-_r ,,-.•--'"....
Washdown  in a floating drydock is identical to that: in a graving dock
except that the wastes are  discharged  over  the  side  of  the  dock
instead of into the drainage tunnels.

Integrity  Testing.   Whenever  any  repair  work  is performed on the
structure, fittings of a pressure vessel such as boilers, or  whenever
repair  work  involves  penetration  of ship*s hull for weld repair of
cracks or similar procedures, the final step in the process must be  a
test  to  demonstrate  the  strength  or  watertight  integrity of the
completed repair.

Although it is not necessary that a ship  be  in  drydock  to  perform
repairs  to pressure vessel equipment, this kind of work is frequently
performed  while  a  ship  is  drydocked.   The  us vial  procedure  for
hydrostatic  testing .of pressure vessel equipment starts with a water
rinse of the inside walls.  The quality of water used depends  on  the
type  of  equipment.  Obviously, non-potable water is not permitted to
enter a potable water system.  Next,  the  equipment  is  filled  with
water of appropriate quality.  Air is applied at test pressure and the
equipment  examined  for  leaks.   The  rinse  and test water might be
discharged to the drydock but is more likely to be clumped to a holding
tank on the ship for later use.             "-*•-
                                         -  • .— &*-.,- s - <;"•.•;••
When repairs involving penetration of the hull of ship are  performed,
the  watertight integrity of the completed repair is usually tested in
two ways.  The first and preliminary method is to apply a stream  from
a  high  pressure  fire  hose on the repaired area while examining the
other side for leaks.  The final method of testing is performed  as  a
part  of  the  undocking  cycle.  When the water level reaches a point
just prior to floating the ship off of the blocks flooding or  sinking
is  stopped  while  a thorough inspection for leaks is made inside the
ship with particular attention to repaired areas.

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PROCESS WASTE CHARACTERIZ ATION

Ship Originating Wastes

When a ship is drydocked, the quantity of wastewater generated depends
upon the expected length of stay in dock and upon specific  operations
being  performed  on  the  ship  during the docking cycle.  Generally,
ships drydocked for short periods and minor repairs operate as if they
are berthed at a pier.  They require potable and non-potable water and
generate wastewater.  On other occasions when ships are drydocked  for
extensive overhaul, they may use little or no water.  At the beginning
of  the  docking period, the consumption of water for such purposes as
cooling is at its peak.  As systems that  use  water  are  shut  down,
water use decreases.  A ship undergoing maintenance on its non-potable
water system or with its crew disembarked may use no water.

After  the  dock is dewatered, threaded studs are spot-welded onto the
ship's hull, and metal scupper boxes  are  bolted  on  at  each  water
discharge location.  Soil chutes then are hoseclamped onto the scupper
boxes  and  suspended  from  the hull.  Soil chutes are flexible hoses
usually made of rubber-coated nylon or canvas.  The lower end of  each
soil  chute  is  fastened  to  the  appropriate  disposal  system; for
example, cooling water to dock overboard  discharge  systems.   Enough
slack  is left in the chute so it can be pushed aside if it interferes
with rolling equipment.  If soil chutes are properly maintained,  this
system  is  an effective means of segregating and carrying away ship's
wastewater.  It would be desirable for the industry to adopt a uniform
standard for hose connections so as to eliminate connection leakage.

Cooling Water.  As mentioned in the paragraph on Cooling Water, except
for a  slight  temperature  increase,  non-contact  cooling  water  is
discharged  from  the  ship  into  the drydock in essentially the same
condition  as  supplied  from  the  drydock  non-potable  water  main.
Reference 5 reports the following measurements taken at one West Coast
facility: nonpotable water supplied at 55°F; non-contact cooling water
discharged  at  58°F;  drainage sump temperature measured at 60°F; and
groundwater infiltration, in comparable volume to  the  cooling  water
discharge, at 70°F.

Boiler  Water.  When ship* s boilers are to be out of service for short
periods, the preferred practice is to keep  them  completely  full  of
very  pure  water.  Under these conditions, there is no discharge.  In
some cases, during maintenance or repair work performed on the  boiler
while  a ship is in drydock, it may be necessary to pump the water out
of the boiler.  This one-time discharge will be slightly alkaline  and
contain a mixed sludge made up of phosphate and carbonate.  The volume
of  this  one-time  discharge  is  approximately  twice  the  steaming
capacity of the boiler.

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      Discharges.  Pumping oily wastewater overboard  from  bilges  is
prohibited  by  Coast  Guard  Regulations.  If an accidental discharge
should occur, it is treated as an oil spill  within  the  drydock  and
clean  up  is performed before discharge to ambient waters.   If an oil
spill occurs during flooding or dewatering operations,  the   operation
is stopped until the oil spill is cleaned up.

Other.   Although  there  are  other discharges from the ship,  such as
wastes from the cleaning of tanks and voids,  they  are  generated  by
drydock  industrial  activity  rather  than  ship  operations  and are
therefore discussed in Hull Cleaning Waste below.

Dock Originating Wastes

Hull Cleaning Waste.  Several methods are used to remove paint,  rust,
and  marine  growth,  such  as  barnacles  and  algae,  from the metal
surfaces of ship hulls.  In all types of surface preparation, the  old
paint,  rust,  and  marine  organisms  are  found  mixed  in the spent
blasting media.  The surface  preparation  methods  are  dry  abrasive
blasting,  hydroblasting,  wet   blasting,  water  cone  blasting, and
chemical paint stripping.  Surface preparation methods, other than dry
blasting, are not common in  the  industry.   Hydroblasting  is  being
tried  at  three  of  the shipyards contacted.  Wet blasting and water
cone blasting is confined principally to  Navy  ships  having  special
coatings.  Chemical paint stripping is rare and is used only on small,
localized  areas  made  of  more  delicate  materials.  Each method is
explained in greater detail below.

Dry abrasive blasting   (sandblasting,  grit  blasting),  is  the  most
common  merhod of surface preparation.  This method is used in varying
detrees by 95 percent of shipyards contacted.   When  employed,  spent
abrasive  is  the principal source of solids in the drydock discharge.
Particle sizes of the used grit range from fine dust to whole bits  of
abrasive,  approximately  one-eighth  inch   in  diameter.  Some of the
soent orit falls directly into drainage gutters, especially if a  ship
is large and the hull sits over the drains*  The potential also exists
for  the  abrasive  to  be  washed  into the drains from storm runoff,
shipboard wastewaters dumped on the dock, hosing,  seepage,  or  other
sources of water.   The spent grit is, for the most part, settleable.

Sometimes,   sand is  used as the abrasive,  instead of utility slag or
copper  slag.    Delicate  equipment,  such   as   sonar   domes,   are
occasionally sand blasted.  Rare aluminum-clad hulls  are often blasted
with  sand   instead of  grit to minimize metal erosion during blasting.
One   problem  with  using  sand  instead  of slag  is  the    airborne
particulates  which are  high   in   silica.  The major water pollution
problem  from sand usage is the possible discharge  of  solids   in the
waste stream.

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The  major  pollution problem from hydroblasting (Reference 1) is that
the volumes of water used increase the potential that  the  paint  and
grit  will be flushed into the drainage discharge.  Any spilled oil or
solvents used elsewhere might, be washed into drainage gutters.   Since
oxidation  of  the surface of the hull of the ship will prevent a good
bond between the fresh paint and metal, rust inhibitors, which contain
compounds such as sodium nitrite and diammonium phosphate,  are  used.
(In  fact,  dry grit blasting is not performed during rainfall so that
metal will not rust during or  after  blasting).   Antifreeze  may  be
added  to  the  spray.   This  will  be discharged into the wastewater
streams along with the blasting water.  Hydroblasting is not preferred
by ship repair facilities, because the resulting surface  obtained  is
not as suitable for paint adhesion as the surface obtained by dry grit
blasting.

Wet  blasting uses a mixture of grit and water.  The water acts as the
propulsion  medium.   The  solids  discharge   potential,   which   is
characteristic   of   dry   grit  blasting,  exists  as  well  as  the
aforementioned problems of hydroblasting.

Paint may be chemically  stripped,  rather  than  blasted,  from  more
delicate  apparatus  such as sonar domes, antennas and deck machinery.
Small articles may be dipped in some yards.  Chemical paint  stripping
was  not  reported  as  being used in drydocks by any of the shipyards
contacted or visited.

Spent Paint, Rust, and Marine Organisms.  Spent paint  containing  the
priority  pollutants copper, zinc, chromium, and lead, along with iron
oxides  and  marine  organisms  are  removed  from  the  ships  during
blasting.  The paint contributes to the solid load in the waste stream
as  well as being subject to contact with stormwater, flooding waters,
hose water, and water spills.  Additionally, it can be washed, pushed,
or blown into uncovered drains.

Antifouling paints are of  particular  concern.   Toxic  constituents,
such  as  copper  or  organotin  compounds  are  used  in  these paint
formulations.  Rust and marine growth removed from the  sides  of  the
ship may increase quantities of solids in the waste stream.

Fresh  Paints and Solvents.  Fresh paints contain a variety of metals,
such as copper, zinc, chromium and lead, as well as hydrocarbons which
are not present in the  used  paint  removed  from  the  ship*s  hull.
Solvents  generally are hydrocarbon based.  Paints and solvents may be
washed into drains; occasionally they are mixed directly  over  drains
with  spillage  falling  into the drains.  Overspray from the painting
operation is estimated to be between one and two percent.   Paint  was
observed  floating  in  discharge  streams  at  one  facility visited.
Organotin paint applications were not observed in any of the  shipyard
visits.                                                 .  '

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Generally  two  -types  of paints are used on ship*s hulls:  antifouling
and anticorrosive.  Antifouling paints are toxic to prevent the growth
of marine organisms.  Cuprous oxide based paints have;  been  used  for
this  purpose  for  many years.  Increased attention has been recently
given to the  use  of  organotin  antifouling  paints.   Although  the
effects  of  organotin  are  not  well documented, these compounds are
reported to be more effective antifoulants than copper  based  paints,
and require a lower percentage of toxic consituents.

There  is  a  trend  toward epoxy-based anticorrosive paints replacing
vinyl and  vinyl-lead  based  coatings.   Pigment  materials  such  as
lampblack,  red-iron-oxide,  and  titanium  dioxide are added to these
paints.  Anticorrosive additives are included in epoxy-based or  vinyl
base paints, usually in the form of zinc dust.

Grease and Oils.  The major source of grease and oils is fuel oils and
lubricants  spilled  on  drydock floors.  Spills most frequently occur
when fuel and oils are  transferred.   Leaky  hoses  and  connections,
overflow   of  containers,  and  general  carelessness  contribute .to
spillage.  When stripping fuel tanks, compartments, and when machinery
is repaired, or a tank ruptures, oil and  grease  pollution  potential
increases.   Spills  can  occur  during refilling of fuel tanks at the
conclusion of the drydock operations.  It is reported that spills over
100 gallons are rare.

Stormwater Runoff.  Stormwater is a totally uncontrollable  source  of
wastewater  in  drydocks.   No method of confining rainfall within the
dock exists.  Channels have been used to direct  the  water  from  the
dock  floor.  The major contribution of Stormwater to wastewater loads
is to increase the quantity of discharge.  When  heavy  and  sustained
rainfalls  occur, Stormwater may transport solids to the drains.  Some
drydocks located in dry climates have essentially no problems  due  to
rainwater.

Dock and Gate Seepage.  Another source of wastewater is leakage around
the caisson gate of graving docks.  This flow of harbor water into the
dock  can  be  caused  by  deterioration of the gate seals or by large
pieces of refuse being trapped between the gate and the dock when  the
caisson  is  replaced  before dewatering.  This water flows across the
floor and into the drainage system.  Some graving docks  are  designed
to  allow  relief  of  hydrostatic  groundwater  pressures through the
sidewalls and floor.  Relief waters also flow  across  the  floor  and
into the drain system.                _-.
                                       .' •" ~w : r, i~, ~~\r-: -
In  some  dock  designs this water is isolated from the dock floor via
dams and drains and is channeled directly into the drainage  trenches.
Flows  approaching 100 gal/minute are not uncommon.  Floor originating
relief waters commonly  flow  across  the  dock  basin  and  into  the
drainage system.
                                 50

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Cleaning Waste.  Detergents are used to clean water tanks, bilges, and
fuel  tanks.   The detergents are combined with diesel oil in a one to
ten ratio.  After cleaning, tanks are rinsed  with  hot  water.   This
process  is  a  source  of  oil  and  grease  as  well as nitrogen and
phosphorus compounds.

On rare occasions, delicate equipment,  such  as  antennas  and  sonar
domes, may be cleaned with detergents prior to painting..

Trash.   Cans,  paper,  bottles,  rags, welding rods, scrap metal, and
pieces of wood are examples of trash found on a drydock floor prior to
flooding.  During dewatering, some of these wastes may be flushed  out
of the docks if they have not been removed.

QUANTITATIVE DATA           .                 .     ,

During the past several years, monitoring programs have been conducted
at  several  shipyards.   Some  of  the  studies were performed by the
shipyards while others were conducted by  the  government.   Effluents
from  two  shipyards were sampled for this document and the results of
all of these studies are  compared  in  this  section.   Additionally,
leaching  studies  are  analyzed  as  well  as  the results of a sieve
analysis of abrasive collected at one shipyard.  Also included in this
section is  a  discussion  of  the  difficulties  and  limitations  of
effectively monitoring shipyard effluents.

Sampling Results

Tables  V-2  through  V-10  indicate  ranges  and  medians  of results
obtained during various sampling programs at shipyards  A,  B  and  D.
Tables  V-7  and V-10 combine the results of all data from Shipyards A
and D respectively according to  different  aspects  of  the  effluent
discharge.

Table  V-2,  for Shipyard A is derived from NPDES monitoring conducted
by shipyard personnel.  A monthly grab sample of the harbor water  was
obtained  at the time of flooding.  While a ship was docked, multi-day
composites were collected at drainage pump discharges.

Several sets of data exist for Shipyard B.  Both shipyard and EPA test
results of the sane sampling program are summarized  (Tables V-3 and V-
U).  This monitoring occurred during research for the Denver Rationale
 (Reference  2).  Major differences   in  results  are  probably  due  to
variations  in  laboratory  techniques.   For example, chromium levels
found in the EPA results of the split  sample  are  much  higher  -than
shipyard  findings.   This  is  due to the use by EPA of a glass fiber
filter and  a  Whatman  tl  paper  filter  during  sample  preparation.
Additionally,  limits  on  the  accuracy  of  the  testing methods may
                                  51

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explain discrepancies such as higher values for dissolved solids  -than
the corresponding -total solids.

Heavy  blasting  and  extensive painting of the docked vessel occurred
during the sampling period.  Because the purpose of these tests was to
prepare the Denver study (Reference 5), and was prior to the  issuance
of NPDES permits, extensive clean up was not dictated.

Grab  samples  were  collected and composited during initial and final
flooding and de water ing, a total of four  composited!  samples.   Also,
two  sequential  samplers  programmed to draw one sample per hour were
used to gain composited daily drainage samples.
                                                  ,*. . ~   :" .
NPDES permit monitoring data on dock  drainage  was  available  for  a
thirteen-month period beginning February 1975.  The shipyard initiated
clean-up  practices  only  during the final month, February 1976.  The
drainage pump discharge was sampled once per month by yard  personnel.
Two  or  three  grab  samples  were  taken  during  a  pump  cycle and
composited (see Table V-5) .

Hittman Associates, under contract to EPA, conducted a sampling  study
in  April 1976.  Grab samples of the harbor water were collected prior
to initial flooding and of initial and final flooded docks.   Also,  a
grab  sample  was  obtained  at every two-foot drop in the water level
during the initial and final dewaterings.   These  samples  were  then
composited.    Additionally,   combined  samples  were  collected  and
documented during  drainage  pump  cycles  throughout  the  monitoring
period.  Table V-6 presents the results of these tests.

During  sampling  at  shipyard  B, a "very light sand sweep11  (32 to 35
tons of grit) of the docked ship, an ore carrier, took place, followed
by anticorrosive touch-up painting,  and  application  of  antifouling
paint.   The hull was blasted to the light load line only.  Hoses were
used to transport most of the shipboard waters to drain channels.   At
times, cooling water fell directly on the dock floor.  Clean up, using
manual  shovels  and  front  end  loaders,  took  place  just prior to
flooding and undocking of the ship.     l*.^r  "L."  ,         "

Comparison of the various test results  presents  few  contradictions.
In  nearly  all  cases, the minimum and median values were consistent.
On rare occasions, high values did  differ  considerably.   Table  V-7
composites  the  data  on  Shipyard  B.   Regardless  of the extent of
painting, effluent levels  remain  constant.   There  is  no  apparent
significant  change  in  Shipyard  B«s  NPDES  monitoring data during,
before,  and  after  clean-up  procedures  were  initiated.   It   is,
therefore, concluded that the nature of the discharge is not conducive
to numerical monitoring.
                                 52

-------
Data for Shipyard D include both NPDES monitoring for 1975 (Table v-8)
and  sampling  from  May 1976 conducted for EPA (Table V-9).   Shipyard
personnel sampled during the second or third week of each month.    The
date  was chosen and sampling occurred regardless of shipyard activity
or weather conditions.  Two samples were  collected  from  each  drain
discharge, separately composited, and reported to fulfill NPDES permit
requirements.

The  May  1976  sampling  thoroughly  covered  the  docking procedure,
including drainage discharges, regularly for ten days until  the  dock
had  been  cleaned.   Manual  shoveling  and  sweeping,  use  of front
loaders, and occasional hosing were performed to clean up 150 tons  of
spent  abrasive used during the blasting to bare metal of the complete
hull of a mediumsized Navy ship.  Use of a closed cycle  side  blaster
on  about  25 percent of the ship's hull limited the abrasive tonnage.
Anticorrosive paint was then applied immediately to the  ship's  hull.
Antifouling paints were not applied during this sampling period.

The  sampling  program  included  samples of the harbor water prior to
flooding  as  well  as  two  additional  harbor  samples  during   the
monitoring period.
                                 53

-------
        Table V-2.  SUMMARY OF NPDES MONITORING AT SHIPYARD A
                  AUGUST 1975 THROUGH SEPTEMBER 1975
                    Harbor Water
                         Pange
Parameter
                              LOW
pH
Suspended Solids
Settleable Solids
Oil and Grease ,
PbT-
PbD
CrT
CrD
CUT
CUD
SnT
SnD
CdT
CdD
ZnT
ZnD
AST
ASD
HgT
BgD
6.9
9.0
<0.1
8.2
<0.05
<0.05
0.02
0.03
0.47
O.OU
<0.7
<0.7
<0.01
<0.01
0.149
0.066
0.02
0.02
0.0035
0.0007
6.7
6.0
<0. 1
1.2
<0.04
<0.04
<0.03
<0.02
0.2
0.03
<0.4
<0.4
<0.01
<0.01
0.054
0.027
<0.01
<0.01
0.0025
0.0004
Drainage Water
     Range
High      Low
7..0
10..0
0..1
43.. 8 2
<0. 05
<0 . 05
<0.03
<0.03
0.54
0.04
<0.7
<0.7
<0.01
<0.01
0.125
0.04
0.04
0.04
0.018
0.0005
6.8
10.0
<0. 1
1.71
<0.04
<0.04
0.02
0.01
0.36
0.04
<0.4
<0.4
<0.01
<0.01
0.049
0.038
<0.01
<0.01
0.0002
0.0004
All values except  pH  are  in mg/1.
                                  54

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A  grab  sample  of  the flooded dock was collected and a composite of
samples collected at each two-foot water level drop  was  made  during
dewatering.   Samples were taken of the drainage water during hosedown
following initial dewatering and regularly throughout  the  monitoring
period.   Every  two  minutes  during  the pumping cycle, samples were
drawn and composited.

During the May 1976 sampling program at Shipyard D, the  harbor  water
was  actually  higher in certain constituents, such as total suspended
solids and pH, than in the  NPDES  tests.   No  significant  increases
occurred between corresponding influents and effluents.  As in samples
at  other  shipyards,  discharge  levels tend to be very low With rare
"high" values of certain parameters.  It could not be established that
dockside activities affect  discharge  levels.   As  in  the  case  of
Shipyards  A  and  B,  constituent  levels remain constant throughout.
Only levels of manganese varied from the harbor water  concentrations.
In  all likelihood, this can be attributed to groundwater infiltration
since no other major source of manganese  is  apparent.   The  results
again  lead  to the conclusion that the nature of the discharge is not
conducive to numerical monitoring.

Several  obstacles  exist  with  respect  to  conducting  an  accurate
sampling  program  of floating drydocks and/or graving docks.  Some of
these problems are due to the nature  of  the  operation  and  drydock
design.  Other difficulties occur during interpretation of the data.

     o    The physical design and operation of a floating  drydock  is
          not  conducive  to conducting an effective sampling program.
          During submersion of the dock, potential  contaminants  such
          as  grit  and paint might be flushed from the surface of the
          dock, rather than discharged through a single sampling point
          such as a pipe or sewer, as in the case with graving docks.

          When the dock is  submerged,  grit,  spent  paint,  oil  and
          grease,  and  other  dockside  wastes  may be flushed or may
          float from the  dock  floor.   Any  spills,  stormwater,  or
          discharges  onto  the  floated dock floors will randomly run
          off the ends and through scuppers along  the  sides  of  the
          floating   drydock.   Since  there  are  multiple  discharge
          points, accurate sampling is not feasible.

     o    Because only total drainage discharges were monitored  on  a
          daily  basis,  it is difficult to attribute constituents and
          flows to any individual source or operation.   For  example,
          variations  in  flows  and  composition of cooling water and
          degree of hydrostatic relief might occur  concurrently  with
          an  operation  such as blasting or painting.  Any alteration
          in drainage discharge would be difficult to  correlate  with
          these activities.
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          Shipyard D management once attempted to estimate  all  drydock
          discharge parameters and levels but were unable to determine
          the  source  of  some  of  the  contaminants-   The  problem
          obviously is complex.

     o    Insufficient documentation of  sampling  programs  performed
          prior  to  this  contract  makes  interpretation  of previous
          monitoring  questionable.   By  failing  to   explain   what
          shipyard  operations  were  in progress, weather  conditions,
          floor  conditions,   and  especially  analytical  procedures,
          interpretation   and   comparison   of  monitoring data  is
          difficult.

     o    The lack of a "typical" daily dock operation means that  all
          data  obtained is particular to that specific day and is not
          necessarily representative of the usual drydock  discharges.
          Consequently  interpretation of the data is difficult.   This
          restricts determination  of  sources  and  establishment  of
          recommendations.

Leaching Studies

Studies  of  the leachability of the fresh abrasive and spent abrasive
and paint  were  done  at  several  shipyards.   The  experiments  are
discussed below.                                                  >

Leaching  Study  tl  consisted  of an experiment in which 400 grams of
spent abrasive collected from a shipyard facility were  mixed  with  a
liter  of seawater.  The combination was shaken intermittently.  A 100
ml aliquot was withdrawn after two days one inch  below  the  surface.
Another  aliquot  was  withdrawn  after  eight  days.   The  method of
analysis was not defined.  The two aliquots produced no difference  in
concentrations  of Cd, Cr, Zn, Cu, and Sn.  Only levels of lead showed
a significant increase.

The  results  of  leaching  Study  f2   present   markedly   different
conclusions.   These  tests  performed  by EPA indicate that the spent
abrasive may actually act as an adsorbent of metals already present in
the water.  Approximately 100  grams of  spent  abrasive  collected  at
five  different shipyards were each exposed to approximately one Ixter
of seawater  from the local bay.  An analysis indicated  that  cadmium,
chromium,  lead,  and  tin  levels  all  either  remain  the  same  or
decreased.   Only   copper  and zinc   exhibited   -any   increase   in
concentration.

Leaching  Study f3 resulted in  no major change  in nickel, zinc, tin, or
cadmium.   Slight  increases in chromium, copper,  iron, and lead levels
occurred, but mercury concentration was  reduced  98 percent.

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The data for Leaching Study i4 was much more  thorough.   Seven  spent
abrasive  samples  and  two fresh abrasive samples were subjected to a
leaching test in seawater.  A level of pollutant was determined  after
exposure  of  300  hours  and  700  hours.   Only  lead concentrations
markedly increased with each sample.  Copper and zinc levels increased
significantly on occasions, but otherwise remained constant.  Arsenic,
cadmium, mercury, and tin  concentrations  never  varied  appreciably.
Levels   of   copper,  lead,  and  zinc  in  the  liquid  consistantly
corresponded to the levels  in  the  spent  abrasive.   Similarly  low
values  of  these metals in the liquid samples occurred when the spent
abrasive contained lesser quantities of these three elements.

Leaching Study f5 consisted of treating five different samples of grit
and river sediment with river water or deionized water.  Some  of  the
experiments  involved stirring, while others did not.  Chromium levels
actually showed a slight  decrease  in  value,  indicating  again  the
possibility  that  the abrasive acts in certain cases as an adsorbent.
Copper levels changed very little.  Data on leachability of  zinc  was
inconclusive  since concentrations of zinc increased in some instances
and decreased in others,

There are many inconsistencies in the results  of  the  five  leaching
studies reviewed.  Questions which remain about testing procedures and
conflicting  data  indicate  that  further  study would be beneficial.
Doubts exist about the reliability of a leaching test done in a  small
closed container where dilution and circulation are not factors.

Sieve Analyses of Debris

Sieve  analyses  were  conducted  on  fresh  grit  and spent paint and
abrasive collected by  the  contractor  at  Shipyard  B.   One  sample
consisted entirely of fresh abrasive, and the second sample containing
spent  paint and grit was collected from the drydock floor immediately
following blasting.  The two samples were analyzed  using  a  standard
sieve analysis and the results are shown in Table V-ll and V-12.

                   Table V-11.  GRAIN- SIZE ANALYSIS
                      OF UNSPENT GRIT  (SAMPLE 1)

Sieve                % Retained          % Finer

   10                    15                 85
   HO                    83                 2
   60                     1.8                .2
  200                     <. 1                <. 1
 <200                     <. 1                <- 1
                       100

 Average specific  gravity = 4.617


                                  65

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                 Table V-12.  GRAIN-SIZE ANALYSIS OF
                SPENT GRIT AND SPENT PAINT  (SAMPLE 2)

Sieve               % Retained          % Finer

  10                   10                90
  40                   78                1?
  60                    66
 140                    3                 3
 200                    1                 2
<200                  	2_                1
                      100

Average specific gravity =4.418

The  fresh  grit,  "Black  Beauty,"  was purchased by the company from
power plants.  The abrasive is actually the slag collected from  coal-
fired  boilers.   The  principal  constituents are iron, aluminum, and
silicon oxides (see Table III-3).  The spent  grit  and  paint,  which
were  collected  following a "very light sand sweep," contained flakes
and particles of antifouling  and  primer  paints  aind  bits  of  iron
oxides.   The  test  results  indicate  that  over  95  percent of the
particles in each sample were sand size and were  regained  in  U.S.A.
Standard  Testing  sieves  numbered 10, 40, 60, and 140, made by Tyler
Equipment Co., with the largest fraction retained in sieve number  40.
The  unspent  grit  particles were slightly larger aind the facets were
sharper and more defined.  The specific gravities of the  two  samples
did  not differ significantly.  These sand-size particles were readily
settleable.
                                 66

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                              SECTION VI

                  SELECTION OF POLLUTION PARAMETERS


INTRODUCTION

Materials originating from shipbuilding and  repair  activities  which
may  have  significance  as  potential pollutants have been identified
during the course of this  study.   Although  an  exhaustive  list  of
materials  capable  of discharge to waterways could be developed, many
of  these  can  be  eliminated  from  consideration.    The   priority
pollutants  copper/ zinc,  chromium, and lead have been identified as
being present in shipyard facilities under conditions which can result
in their discharge.  Compounds of these  metals  are  constituents  of
fresh  paints   (Tables III-4 and III-5).  They persist in the abrasive
blasting debris as components of the spent paint  and  abrasive.   Tne
rationale for selection of constituents as pollution parameters or for
rejection of others is presented here.

While  numerical guidelines and standards are not being recommended at
this time, pollution parameters are being identified for consideration
by the users of this document and for further investigation,  and  use
where it may be appropriate.

Factors   which  have  been  considered  in  selecting  and  rejecting
pollution parameters include:

     o    The degree of pollutional constituents used  and  discharged
          from  ship   repair  and  construction  operations in  graving
          docks and floating drydocks.

     o    The need for preventing the introduction  of the  constituent
          into  the waterway;  and

     o    The aesthetic  effects  of the  constituent  and the effects   on
          other uses of  the water.

 A  list of  constituents  which may be subject to  discharge  from graving
 docks and from  floating  drydocks is  shown in  Table  VI-1.    Pollution
 parameters  have been  selected from  this list,  and this  is  discussed in
 the following sections.
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Table   VI-1.   MATERIALS  ORIGINATING   FROM
DISCHARGED TO WATERWAYS
                          DRYDOCKS  WHICH  MAY  BE
Constituents

Fresh Grit




Blasting Debris




Solid Wastes




Fresh Paint
Oil & Grease
Fuel
Oil, Grease and
Fuel Contaminated
Water

Solvents, Paint
Remover

Boiler Water
Cooling Water
Hydrostatic
Leakage

Gate Leakage
     Source

Spills during transfer
and handling
Material removed from
ships hull during
blasting
Repair and Construc-
tion Activities
Paint mixing spills,
overspray
Spills and leakage
from ship and equip-
ment, losses during
servicing

Leakage from tank
cleaning and ruptured
tanks, bilgewater

Paint stripping
other than blasting

Vessel boiler
Vessel equipment
Groundwater leakage
into dock

Harbor water
     Comments

Uncontaminated
solid, usually slag,
sand, cast iron or
steel shot

Spent grit, marine
fouling, spent paint,
rust, may contain
priority pollutants

Scrap metal, welding
rods, wood, plastics,
trash such as paper
and food scraps

Overspray may reach
dock floor, spills
to floor or drains
and contains prior-
ity pollutants

Can originate either
from vetssel or from
dock activities
May contain detergents
used in tank cleaning
Not common practice
High quality water,
usually not discharged

Supplied by on-shore
source, once-through,
non-contact

Graving docks only
Graving docks only
                                 68

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Materials identified in Table VI-1 may produce other  contaminants  in
water.   Their  effects  are generally measured in terms of parameters
such as suspended solids, dissolved  solids,  BOD  and  COD,  oil  and
grease,  and  specific elements or chemical species.  Table VI-2 lists
specific and nonspecific parameters  which  are  possible  pollutants.
Analytical  methods  for  monitoring would necessarily include some or
all of the items listed in Table VI-2.

                                                         .           *
      Table VI-2.  PARAMETERS WHICH MAY BE PRESENT IN
            WASTEWATER DISCHARGES FROM DRYDOCKS


    Specific Parameters            Non-specific
     Metals      Non-Metals         Parameters

     Pb  Mn         P0«       pH

     Cr  As         NO2       Total Suspended Solids

     Cu  Hg                   Settleable Solids

     Sa  Ni                   Oil and Grease

     Cd  Al

     Zn  Fe


RATIONALE FOR THE SELECTION OF POLLUTION PARAMETERS

During the course of this study and the sampling program conducted  in
support  of  it,  it has become evident that a direct cause and effect
relationship between activities and materials in the docking  facility
and  constituents  in  the  wastewater  does  not  always  exist.   In
addition, much of the water purposefully used in drydocking operations
is harbor water already containing measurable levels  of  constituents
leached  from  the drainage area supplying the harbor, discharged from
other sources, or naturally present in the water.   Because  of  this,
the  problem  of  identifying the origin of these constituents, in the
presence of sampling and analytical variations, becomes complex.

In selecting pollution parameters two questions have  been  considered
as  vital  to  the proper inclusion of a constituent in this category.
The first of  these  is,  "Are  the  constituents  discharged  to  the
environment"?  Second,  and  equally important is, "Is the constituent
present in the ship repair and construction facility  in  a  condition
capable of creating a hazardous discharge"? If both of these questions
can  be  answered  in  the  affirmative,  the  constituent  should  be
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considered a potential pollutant
necessitating controls.
requiring  monitoring  and  possibly
Referring  to Table VI-2, the listed metals all may be constituents of
the paint used on hulls.  The most commonly used anticorrosive  paints
contain  zinc  chromate  or lead oxide.  Antifouling paints in current
use usually incorporate cuprous oxide.  The use of arsenic and mercury
antifouling paints has been discontinued because  of  their  toxicity.
Recently,  antifouling paints containing organotin compounds have been
introduced into practice.  These have the advantage of longer life  in
service  but  when  removed for repainting, like mercury based paints,
can be  toxic  to  workers.   Three  sources  of  iron  exist  in  the
drydocking  facility.   Steel scrap and waste metal are major sources.
Iron from scrap is initially in the metallic form Jout air and moisture
will rapidly produce a surface coat of rust.   The  second  source  is
iron oxide contained in the paints.  The amount of iron oxide in paint
is  negligible  compared  to the other paint components and to exposed
steel surfaces found  in  the  drydock  area.   The  third  source  is
metallic   iron  abraded  from  ships  during  abrasive  blasting  and
subsequent potential dissolution into water.

Non-metal constituents are phosphates and nitrites.  These  are  added
to  water in trace quantities during wet blasting to bare metal.  They
function as rust  inhibitors.   Their  use  is  infrequent  and  total
quantities are small.

Non-specific   parameters  which  may  ultimately  be  transported  to
wastewater are also listed in Table VI-2.

Solids content is measured by total solids, suspended  and  settleable
solids,  and  dissolved  solids.   Total  solids  is  the total of the
suspended and dissolved components.  Most of the suspended solids  are(
spent  paint  and  grit  from  the  blasting  operations, but may also
include dried fresh paint resulting from overspray and spills.   Other
sources of solids are metal or metal scale particulates resulting from
cutting  and  cleaning  work,  slag  from  arc weldiLng, wood and other
organic solids particles, etc., all in  small  quantities.   Dissolved
solids  may  be present due to constituents from spent or fresh paint,
solution of iron or alloy metals from scrap  steel,  and  solution  of
components from virtually any solid coming in contact with water.

A  measure of the hydrogen ion concentration of water is pH.  As such,
it can be altered (from the neutral value of 7)  to  either  acidic  or
basic values by the effects of dissolved materials added to the water.

Oil  and  grease  are  measures  of  the quantity of organic compounds
extractable by hexane.  This can include not only  oils  and  greases,
but also fuel, solvents, and paint components.
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The parameters selected as pollutants potentially released by shipyard
activities   into   wastewaters  are  listed  in  Table  VI-3.   These
constituents represent materials which are commonly, used in drydocking
facilities and hence which  have  potential  for  release  to  ambient
waters.   Although  other  parameters  listed  in Table VI-2 have been
rejected as pollutants to be regulated at this time, the sampling  and
analysis  program  routinely  determined  the levels of those as well.
The basis for rejection is discussed in the subsection  on  "Rationale
for Rejection of Pollution Parameters."


               Table VI-3.  POLLUTION PARAMETERS


        Specific Parameters .
       Priority                    Other        Non-Specific
       Pollutants   Non-Metals     Metals        Parameters

          Zn        None             Sn*       Suspended Solids
          Cu                                   Settleable Solids
          Pb                                   Oil and Grease
          Cr                                   pH

     *Only where organotin anti-fouling plants may be
      used or removed from the hull.

It  must  be  emphasized  that  one  of  the  great  uncertainties  in
establishing pollution parameters arises from the use of harbor  water
for  most  of  the  shipyard  operations.   Unlike chemical processing
plants, where high quality water is used,  input  water  may  vary  in
constituent  concentration  fron  fresh lake and river water to saline
ocean water, thus the background content of  suspended  and  dissolved
components  may mask many of the parameters frequently monitored.  The
following subsections discuss  each  of  the  parameters  selected  as
potential pollutants.

Zinc (Zn)

Occurring abundantly in rocks and ores, zinc is readily refined into a
stable  pure metal and is used extensively as a metal, an alloy, and a
plating material.  In addition, zinc salts  are  also  used  in  paint
pigments,  dyes,  and insecticides.  Many of these salts (for example,
zinc chloride and zinc sulfate) are highly soluble in water; hence, it
is expected that zinc might occur in many industrial wastes.   On  the
other hand, some zinc salts (zinc carbonate, zinc oxide, zinc sulfide)
are  insoluble  in  water  and, consequently, it is expected that some
zinc will precipitate and be removed readily in many natural waters.
                                 71

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In soft water, concentrations of zinc ranging from  0.1  to  1.0  mg/1
have been reported to be lethal to fish.  Zinc is thought to exert its
toxic  action  by  forming  insoluble  compounds  with the mucous that
covers the gills, by damage to the gill  epithelium,  or  possibly  by
acting  as an internal poison.  The sensitivity of fish to zinc varies
with species, age, and condition, as well as  with  the  physical  and
chemical  characteristics  of  the water.  Some acclimatization to the
presence of the.zinc is possible.  It has also been observed that  the
effects  of zinc poisoning may not become apparent immediately so that
fish removed from zinc-contaminated to zinc-free water may die as long
as 'US hours after the removal.  The presence of copper  in  water  may
increase the toxicity of zinc to aquatic organisms, while the presence
of calcium or hardness may decrease the relative toxicity.

A  complex  relationship exists between zinc concentrations, dissolved
oxygen, pH, temperature, and  calcium  and  magnesium  concentrations.
Prediction  of  harmful  effects  has  been  less  than  reliable  and
controlled studies have not been extensively documented..

Concentrations of zinc in excess of 5  mg/1  in  public  water  supply
sources cause an undesirable taste which persists through conventional
treatment.  Zinc can have an adverse effect on man eind animals at high
concentrations.

Observed  values  for  the  distribution  of zinc i*i ocean waters vary
widely.  The major concern with zinc compounds in marine waters is not
one of acute lethal effects, but rather one of the long term sublethal
effects of the metallic compounds and complexes.  From  the  point  of
view  of  acute lethal effects, invertebrate marine animals seem to be
the most sensitive organisms tested.

A variety of freshwater plants tested manifested harmful  symptoms  at
concentrations  of  10  mg/1.   Zinc sulfate has also been found to be
lethal to many plants and it could impair  agricultural  uses  of  the
water.

Copper (Cu)

Copper  is  an  elemental metal that is sometimes found free in nature
and is found in many minerals such  as  cuprite,  meilachite,  azurite,
chalcopyrite,  and  hornite.   Copper  is  obtained from these ores by
smelting, leaching, and electrolysis.  Significant industrial uses are
in  the  plating,  electrical,   plumbing,   and   heating   equipment
industries.   Copper  is  also commonly used with other minerals as an
insecticide and' fungicide.

Traces of copper are found in all forms of plant and animal life,  and
it  is  an  essential  trace  element  for  nutrition.   Copper is not
considered to be a cumulative systemic poison  for  humans  as  it  is
                                 72

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readily   excreted   by  the  body,  but  it  can  cause  symptoms  of
gastroenteritis, with nausea and intestinal irritations, at relatively
low dosages.  The limiting factor in domestic water supplies is taste.
Threshold concentrations for taste have been generally reported in the
range of 1.0 to 2.0 mg/1 of copper while concentrations of  5  to  7.5
mg/1  have made water completely undrinkable.  It has been recommended
that the copper in public water supply sources not exceed 1 mg/1.

Copper salts cause undesirable color reactions in  the  food  industry
and cause pitting when deposited on some other metals such as aluminum
and  galvanized  steel.   The textile industry is affected when copper
salts are present in water used for processing of fabrics.  Irrigation
waters containing  more  than  minute  quantities  of  copper  can  be
detrimental  to  certain  crops.   The  toxicity  of copper to aquatic
organisms varies significantly, not only with the  species,  but  also
with the physical and chemical characteristics of the water, including
temperature, hardness, turbidity, and carbon dioxide content.  In hard
water,   the   toxicity   of  copper  salts  may  be  reduced  by  the
precipitation of copper carbonate or other insoluble  compounds.   The
sulfates of copper and zinc, and of copper and cadmium are synergistic
.in their toxic effect on fish.

Copper concentrations less than 1 mg/1 have been reported to be toxic,
particularly  in  soft  water,  to  many  kinds  of fish, crustaceans,
mollusks, insects, phytoplankton, and zooplanton.   Concentrations  of
copper,  for  example,  are detrimental to some oysters above 0.1 ppm.
Oysters cultured in seawater containing 0.13  to  0.5  ppm  of  copper
deposited  the  metal  in  their  bodies  and  became  unfit as a food
substance.                                                 "

Tin  (Sn)

Tin is not present in natural water, but it may  occur  in  industrial
wastes.   stannic  and  stannous  chloride  are  used  as mordants for
reviving colors, dyeing fabrics, weighting silk, and tinning  vessels.
Stannic chromate is used in decorating porcelain, and stannic oxide is
used in glass works, dye houses, and for fingernail polishes.  Stannic
sulfide  is  used  in  some lacquers and varnishes.  Tin compounds are
also used in fungicides, insecticides, and anti-helminthics.

No reports have been uncovered to indicate that tin is detrimental  in
domestic  water  supplies.  Traces of tin occur in the human diet from
canned foods, and it has been estimated that the average diet contains
17.14 mg of tin per day.  Man can apparently tolerate 850 to  1000  mg
per day of free tin in his diet.

On  the  basis  of  feeding  experiments,  it  is  unlikely  that  any
concentration of tin that could occur in most natural waters would  be
detrimental  to  livestock.  Most species of fish can withstand fairly
                                 73

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large concentrations of tin; however, tin is about ten times as  toxic
as copper to certain marine organisms such as barnacles and tubeworms.

While  the inorganic compounds of tin are essentially non-toxic at the
levels normally encountered, organotin compounds exhibit a high degree
of toxicity  to  specific  organisms.   These  are  relatively  recent
innovations and little experience has been developed in their use.

Due  to the potential hazards of organotins to marine environments and
in light of the present lack of knowledge concerning the  behavior  of
organotin waste in the environment, abrasive blasting waste containing
organtin compounds should be considered pollutants oi: concern.

Lead (Pb)

Lead  is  used  in  various  solid  forms  both as a pure metal and in
several compounds.  Lead appears in some natural waters, especially in
those areas where mountain limestone and galena are found.   Lead  can
also  be  introduced  into  water from lead pipes by the action of the
water on the lead.

Lead is a toxic material that is foreign to humans and  animals.   The
most  common  form  of lead poisoning is called plumbism.  Lead can be
introduced into the body from the atmosphere containing lead  or  from
food and water.

Lead cannot be easily excreted and is cumulative in the body over long
periods  of time, eventually causing lead poisoning with the ingestion
of an excess of 0.6 mg per day over a period of years.   It  has  been
recommended that 0.05 mg/1 lead not be exceeded in public water supply
sources.

Chronic  lead  poisoning  has occurred among animals at levels of 0.18
mg/1 of lead in soft water and by concentrations  under  2.4  mg/1  in
hard  water.   Farm  animals are poisoned by lead more frequently than
any other poison.  Sources of this occurrence include paint and  water
with  the  lead  in  solution  as  well  as  in suspension.  Each year
thousands of wild waterfowl  are  poisoned  from  lead  shot  that  is
discharged  over  feeding  areas  and  ingested by the waterfowl.  The
bacterial decomposition-of organic matter  is  inhibited  by  lead  at
levels of 0.1 to 0.5 mg/1.                 ^r.oi- r;v   -

Fish  and  other  marine  life  have had adverse effects from lead and
salts  in  their  environment.   Experiments  have  shown  that  small
concentrations of heavy metals, especially of lead, have caused a film
of  coagulated  mucous  to form first over the gills and then over the
entire body probably causing suffocation  of  the  fish  due  to  this
obstructive  layer.  Toxicity of lead is increased with a reduction of
dissolved oxygen concentration in the water.
                                 74

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Chromium (Cr)

Chromium is an elemental metal usually found as a chromite  (FeCr^OO) .
The metal is normally processed by reducing the oxide with aluminum.

Chromium  and  its compounds are used extensively throughout industry.
It is used to harden steel  and  as  an  ingredient  in  other  useful
alloys.   Chromium  is  also used in the electroplating industry as an
ornamental and corrosion resistant plating on steel and can be used in
pigments and as a pickling acid (chromic acid)..

The two most prevalent chromium forms found  in  industry  wastewaters
are  hexavalent and trivalent chromium.  Chromic acid used in industry
is a hexavalent chromium compound which is partially  reduced  to  the
trivalent  form during use.  Chromium can exist as either trivalent or
hexavalent  compounds  in  raw  waste  streams.  Hexavalent   chromium
treatment involves reduction to the trivalent form prior to removal of
chromium from the waste stream as a hydroxide precipitate.

Chromium,  in its various valence states, is hazardous to man.  It can
produce lung tumors when  inhaled  and  induces  skin  sensitizations.
Large  doses  of  chromates  have  corrosive effects on the intestinal
tract and can cause inflammation of the kidneys.  Levels  of  chromate
ions  that  have  no  effect on man appear to be so low as to prohibit
determination to date.  The recommendation for public  water  supplies
is that such supplies contain no more than 0.05 mg/1 total chromium.

The  toxicity  of chromium salts to fish and other aquatic life varies
widely with the species, temperature, pH, valence of the chromium  and
synergistic  or  antagonistic  effects, especially that of hard water.
Studies have shown that trivalent chromium is more toxic  to  fish  of
some  types  than  hexavalent  chromium.   Other  studies  have  shown
opposite effects.  Fish  food  organisms  and  other  lower  forms  of
aquatic  life are extremely sensitive to chromium and it also inhibits
the  growth  of  algae.   Therefore,  both  hexavalent  and  trivalent
chromium must be considered harmful to particular fish or organisms.

Total Suspended Solids  (TSS)

Suspended  solids  include  both  organic  and inorganic materials The
inorganic  compounds  include  sand,  silt,  and  clay.   The  organic
fraction  includes  such materials as grease, oil, tar, and animal and
vegetable waste products.  These solids may  settle  out  rapidly  and
bottom  deposits  are  often  a  mixture of both organic and inorganic
solids.  Solids may be suspended in water for a time, and then  settle
to  the bed of the stream or lake.  These solids discharged with man's
wastes may  be  inert,  slowly  biodegradable  materials,  or— rapidly
decomposable  substances.   While  in  suspension,  they  increase the
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turbidity of the water,  reduce  light  penetration,  and  impair  the
photosynthetic activity of aquatic plants.

Suspended  solids  in  water interfere with many industrial processes,
cause foaming in boilers, and incrustations on  equipment  exposed  to
such water, especially as the temperature rises.  They are undesirable
in  process  water  used  in  the manufacture of steel, in the textile
industry, in laundries, in dyeing, and in cooling systems.

Solids in suspension are aesthetically displeasing.  When they  settle
to  form  sludge  deposits  on  the stream or lake bed, they are often
damaging to the life in water.  Solids,  when  transformed  to  sludge
deposits,  may  do  a variety of damaging things , including blanketing
the stream or lake bed and thereby destroying the  living  spaces  for
those benthic organisms that would otherwise occupy the habitat.  When
of  an  organic  nature,  solids use a portion of all. of the dissolved
oxygen available in the area.  Organic materials also serve as a  food
source for sludgeworms and associated undesirable organisms.

Disregarding  any  toxic effect attributable to substances leached out
by water, suspended solids nay kill  fish  and  shellfish  by  causing
abrasive  injuries  and  by clogging gills and respiratory passages of
various aquatic fauna.  Indirectly, suspended solids are  inimical  to
aquatic  life  because  they  screen  out  light, and they promote and
maintain  the  development  of  noxious  conditions   through   oxygen
depletion.   This  results  in  the  killing  of  fish  and  fish food
organisms.  Suspended solids also reduce the recreational value of the
water.

Oil and Grease

Because of widespread use, oil and grease occur  often  in  wastewater
streams.  These oily wastes may be classified as follows:

     o    Light Hydrocarbons -  These  include  light  fuels  such  as
          gasoline,  kerosene,  jet  fuel,  and miscellaneous solvents
          used for  industrial  processing,  degreasing,  or  cleaning
          purposes.  The presence of these light hydrocarbons may make
          the removal of other heavier oily wastes more difficult.

     o    Heavy Hydrocarbons, Fuels, and  Tars  -  These  include  the
          crude  oils,  diesel  oils, §6 fuel oil, residual oils, slop
          oils, and in some cases, asphalt and road tar.

     o    Lubricants and Cutting Fluids - These  generally  fall  into
          two classes:  non-emulsifiable oils such as lubricating oils
          and  greases  and  emulsifiable  oils  such as water soluble
          oils, rolling oils, cutting  oils,  and  drawing  compounds.
                                  76

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          Emulsifiable  oils  may  contain  fat  soap or various other
          additives.

     o    Vegetable  and  Animal  Fats  and  Oils  -  These  originate
          primarily from processing of foods and natural products.

These compounds can settle or float and may exist as solids or liquids
depending  upon factors such as method of use, production process, and
temperature of wastewater.                              -

Oils and grease even in small quantities cause troublesome  taste  and
otlor  problems.   Scum  lines  from these agents are produced on water
treatment basin walls and other containers.  Fish  and  waterfowl  are
adversely affected by oils in their habitat.  Oil emulsions may adhere
ta  the  gills  of  fish causing suffocation, and the flesh of fish is
tainted when microorganisms that were exposed to waste oil are  eaten.
Deposition  of  oil  in  the  bottom  sediments  of water can serve to
inhibit normal benthic growth.   Oil  and  grease  exhibit  an  oxygen
demand.

Levels  of  oil  and  grease which are toxic to aquatic organisms vary
greatly,  depending  on  the  type  and  the  species  susceptibility.
However,  it has been reported that crude oil in concentrations as low
as 0.. 3 mg/1 is extremely  toxic  to  freshwater  fish.   It  has  been
recommended  that public water supply sources be essentially free from
oil and grease.

Oil and grease in quantities of 100 1/sq km  (10 gallons/sq mile)  show
up  as a sheen on the surface of a body of water.  The presence of oil
slicks prevent the full aesthetic enjoyment of water.  The presence of
oil in water can also increase the toxicity of other substances  being
discharged   into  the  receiving  bodies  of  water.   Municipalities
frequently limit the quantity of oil and grease that can be discharged
t0> their wastewater treatment systems by industry.
                                                •i.i x ji.j a^-9'  ^.srfOjt .•  •
Acidity and Alkalinity  (pH)
                                                   :•-•"•  if-' _.-,".
Although not a specific pollutant, pH is related  to  the  acidity  or
alkalinity  of  a  wastewater  stream.   It  is not a linear or direct
measure of either, however," it may be used properly as a surrogate  to
control  both excess acidity and excess alkalinity in water.  The term
pH is used to describe the hydrogen ion  -  hydroxyl  ion  balance  in
water.  pH measures the hydrogen ion concentration or activity present
in  a given solution.  pH numbers are the negative common logarithm of
tlse hydrogen ion concentration.  A pH of 7 indicates neutrality  or   a
balance  between  free  hydrogen and free hydroxyl ions.  A pH above  7
indicates that the solution is alkaline, while a pH below 7  indicates
that the solution is acid.
                                 77

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Knowledge  of  the  pH of water or wastewater is useful in determining
necessary measures  for  corrosion  control,  pollution  control,  and
disinfection.  Waters with a pH below 6.0 are corrosive to water works
structures,  distribution  lines,  and household plumbing fixtures and
such corrosion can add constituents to drinking water  such  as  iron,
copper,  zinc,  cadmium,  and  lead.   Low  pH waters not only tend to
dissolve  metals  from  structures  and  fixtures  but  also  tend  to
redissolve  or  leach  metals  from sludges and bottom sediments.  The
hydrogen ion concentration can affect the "taste" of the water and  at
a low pH, water tastes "sour."

Extremes of pH or rapid pH changes can exert stress conditions or kill
aquatic  life  outright.   Even  moderate  changes  from  "acceptable"
criteria limits of pH .are deleterious to some specie's.   The  relative
toxicity  to aquatic life of many materials is increased by changes in
the water pH.  For example, metalocyanide  complexes  can  increase  a
thousand-fold in toxicity with a drop of 1.5 pH units.  Similarly, the
toxicity. of  ammonia is a function of pH.  The bactericidal effect of
chlorine in most cases  is  less  as  the  pH  increases,  and  ,it  is
economically advantageous to keep the pH close to 7..,

Acidity  is  defined  as  the  quantitative  ability  of  a  water  to
neutralize hydroxyl ions.  It is  usually  expressed  as  the  calcium
carbonate equivalent of the hydroxyl ions neutralized.  Acidity should
not  be  confused  with pH value.  Acidity is the quantity of hydrogen
ions which may be released to react with or neutralize  hydroxyl  ions
while  pH  is a measure of the free, hydrogen ions in a solution at the
instant the pH measurement is made.  A  property  of  many  chemicals,
called  buffering,  may hold hydrogen ions in a solution from being in
the free state and being measured as pH.  The bond of mpst buffers  is
rather  weak  and hydrogen ions tend to be released from the buffer as
needed to maintain a fixed pH value.

Highly acid waters  are  corrosive  to  metals,  concrete  and  living
organisms,  exhibiting  the pollutional characteristics outlined above
for low pH waters.  Depending on buffering capacity,, water may have  a
higher  total  acidity at pH values of 6.0 than other waters with a pH
value of 4.0.

RATIONALE FOR REJECTION OF POLLUTION PARAMETERS

A number of parameters shown in  Table  VI-2  have  been  rejected  as
pollution parameters.  This rejection was based on negative answers to
one  or  both  of  the  questions used to select pollution parameters.
Rejected parameters are listed in Table VI-4.  A brief  discussion  of
the rejected parameters and the rationale follows.
                                 78

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Table VI-4.  PARAMETERS REJECTED AS POLLUTION PARAMETERS


         Specific Parameters         Non-Spedfie
        Metals      Non-Metals        Parameters

        As  Mn         PO4        Total Solids
        Hg  Al         NO2        Dissolved Solids
        Fe                        COD
        Cd	      BOD
        Ni


Arsenic  has  been  rejected because its use in"antifouling paints has
been discontinued due to toxicity.  Mercury also formerly was included
as a constituent of antifouling paints.  However, on March  29,  1972,
the EPA suspended its use in marine paints, and since that use was not
subject  to  appeal  (although its use in other paint formulations was
appealed),  it  no  longer  is  found  in  shipbuilding   and   repair
facilities.   If further investigation reveals the presence of arsenic
in foreign paints which are subsequently removed in  U.S.  facilities,
then it shall become a selected pollutant.

Iron  has  been rejected because, except for trace quantities in spent
paint both as a pigment component and as rust blasted from the  hulls,
its  presence  in shipbuilding and repair facilities is in the form of
structural steel, or at levels below immediate concern.

Cd, Ni, and Mn  are  unlikely  constituents  to  arise  from  shipyard
operations.   No  uses  of  these  materials  in  shipyards  have been
identified.   Aluminum  may  be  present  but  is  not  considered   a
significant  pollutant.  Aluminum in the form of alum is commonly used
in water treatment plants.

Phosphates and nitrites have been eliminated.   Both  are  potentially
detrimental  to  natural water bodies, but the only source is from wet
blasting to bare metal.  In this operation they are added to the water
in fractional percentages as rust inhibitors.  Wet  blasting  to  bare
metal  is rarely used in shipyard practice because of the formation of
rust on the unpainted surface.

COD and BOD have also been rejected.  COD occurs as a  result  of  the
presence  of  reducing chemical compounds in the wastewater.  The only
reducing chemical species identified are nitrites, and these have been
rejected as a  parameter.   BOD  results  from  biological  (sanitary)
wastes and is not within the scope of this study.
                                 79

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                             SECTION VII

                   TREATMENT AND CONTROL TECHNOLOGY

                                            -•,',-, \
INTRODUCTION
                                            ,: •i.=;--i.;p   !'
Treatment  and  control  of shipyard discharges is subject«*o problems
not encountered in most industries.  One  example  is  the  volume  of
water   involved  in  graving  dock  dewatering  or  raising  floating
drydocks.  Graving dock volumes shown in Table III-8  range  from  3.8
million liters (1.0 million gallons) to 246 million liters (65 million
gallons).   Dewatering may be carried out in four hours or less and at
the upper size extreme the flowrate  during  dewatering  would  be  60
million  liters (16 million gallons) per hour or the equivalent of 476
million liters (390 million gallons) per day.  Floating  drydocks  are
open  ended,  and  confinement  of volumes of water equivalent to that
found in graving docks would make it impossible  to  raise  the  dock.
Thus,  flooding  and  dewatering  operations defy practical wastewater
treatment.                                     --  -

There are, however,  a  number  of  practices  which  can  potentially
benefit  the  discharges  of  industrial  and  other  waters from both
graving docks and floating drydocks.  In the  course  of  this  study,
these practices, which constitute the treatment and control technology
in  use  or  under  development,  were  observed  or  reported  to the
contractor by facilities visited or contacted.   - '

Seven facilities were  visited  and  thirty-eight  were  contacted  by
telephone.   From  the information obtained, the treatment and control
technology in use basically consists of (1) clean-up procedures in the
dock and  (2) control of water flows within the dock.   The  degree  to
which  the  available  control  measures  are  implemented by.any yard
depends  upon  conditions  prevailing  at   the   facility,   physical
constraints  within  the  facility,  economic factors, and, to a large
extent, management philosophy.              r:ii c.

All facilities practice some degree of  clean  up  at  various  times,
although  this  may consist only of moving debris out of the work area
when accumulations interfere  with  operations.   During  the  docking
period, some facilities use extensive clean-up procedures, not only to
remove  debris  prior  to  flooding, but to eliminate possible contact
with gate  leakage,  hydrostatic  water,  or  rainwater.   In  general
drydock  clean up is directed toward improving productivity and safety
and toward maintaining acceptable working conditions.  Both mechanical
and manual methods are in use.
                                 81

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Mechanical clean-up methods used or tried include mechanical sweepers,
front loaders, vacuum equipment and  closed  cycle  blasting.   Manual
methods include shovels, brooms, and hoses.

Control  of  water  flows  within  the dock, like clean-up procedures,
varies with facility.  In some cases, no controls of  wastewater  from
either  the  docked  vessel,  industrial activities, leakage, or other
natural causes are practiced.

Other facilities use methods to control and segregate water  flows  or
have   plans  to  implement  such  control.   Generally,  control  and
segregation of water flows in the dock, when practiced, has  been  for
the  same  purposes  as  clean  up,  i.e.,  productivity,  safety, and
improved working conditions.  However, recently, particularly in naval
facilities, this form of control has the added purpose of  eliminating
potential discharge of pollutants.

In  summary  the  treatment  and  control  technology being applied or
planned for drydocks consists of clean-up procedures and  control  and
segregation  of  water  flows.   The objectives of clean-up activities
are:

     o    To improve productivity by removing physical  obstacles  and
          impediments to men and machinery working in the dock.

     o    To improve safety by  eliminating  hazardous  materials  and
          conditions from the work area.

     o    To improve working conditions  by  eliminating  health   (and
          safety) hazards and factors detrimental to morale.

     o    To prevent potential contaminants from being  discharged  to
          the atmosphere or waterways.

Where  control  and segregation of water flows within the docks are in
use or planned the objectives are:

     o    To  segregate  sanitary  waste,  cooling  water,  industrial
          wastewaters,  and  leakages in order to comply with existing
          regulations governing sanitary wastes.

     o    To comply with existing regulations governing oil spills and
          discharges.

     o    To prevent transport of  solids  to  the  waterway  way  and
          contact of wastewater with debris in the drydock.

Management  practices  consistant with attaining these objectives  have
been defined.  These represent actions and philosophies which  can be
                                  82

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adopted in the normal course of shipyard operations.  As such they can
be   set  forth  in  general  terms,  and  the  particular  conditions
prevailing at each facility will determine the details and methods  of
implementation.  The best management practices are presented below.

The  following  specific  requirements  shall be incorporated in NPDES
permits and are to be  used  as  guidance  in  the  development  of  a
specific  facility  plan.  Best Management Practices  (BMP) numbered 2,
5, 7 and 10 should be considered on a case-by-case basis for yards  in
which  wet  blasting  to  remove paint or dry abrasive blasting do not
occur, and BMP 10 does not apply to floating drydocks.

     BEST MANAGEMENT PRACTICES (BMP)

BMP 1.    Control of Large Solid Materials.   Scrap  metal,  wood  and
          plastic,  miscellaneous  trash  such  as  paper  and  glass,
          industrial scrap and waste such as insulation, welding rods,
          packaging, etc., shall be removed  from  the  drydock  floor
          prior to flooding or sinking.

BMP 2.    Control of Blasting Debris.  Clean-up  of  spent  paint  and
          abrasive  shall  be  undertaken  as  part  of  the repair or
          production activities to the degree technically feasible  to
          prevent  its entry into drainage systems..  Mechanical clean-
          up  may  be  accomplished  by  mechanical  sweepers,   front
          loaders,  or  innovative  equipment.  Manual methods include
          the use of shovels and brooms..  Innovations  and  procedures
          which improve the effectiveness of clean-up operations shall
          be adapted, where they can be demonstrated as preventing the
          discharge  of  solids.   Those portions of the drydock floor
          which are reasonably accessible shall be "scraped or broomed
          clean" of spent abrasive prior to flooding.

          After a vessel has been removed from  the  drydock  and  the
          dock  has  been  deflooded for repositioning of the keel and
          bilge blocks, the remaining areas of the  floor  which  were
          previously  inaccessible  shall  be  cleaned  by scraping or
          broom cleaning prior to the introduction of  another  vessel
          into  the  drydock.  The requirement to clean the previously
          inaccessible area shall be waived  either  in  an  emergency
          situations  or when another vessel is ready to be introduced
          into the drydock within fifteen  (15) hours.  Where tides are
          not a factor, this time shall be eight (8) hours.

BMP 3.    Oil, Grease, and Fuel Spills.  During the  drydocked  period
          oil, grease, or fuel spills shall be prevented from reaching
          drainage  systems  and  from  discharge with drainage water.
          Cleanup shall be carried out promptly after an oil or grease
          spill is detected.
                                 83

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BMP 4.    Paint and Solvent Spills.  Paint and solvent spills shall be
          treated as oil spills and segregated from  discharge  water.
          Spills  shall  be  contained  until  clean-up  is  complete.
          Mixing of paint shall be carried out in locations and  under
          conditions such that spills shall be prevented from entering
          drainage systems and discharging with the drainage water.

BMP 5.    Abrasive Blasting Debris (Graving Docks).  Abrasive blasting
          debris in graving docks shall be  prevented  from  discharge
          with  drainage  water.   Such blasting debris as deposits in
          drainage  channels  shall  be  removed   promptly   and   as
          completely  as  is  feasible.   In some cases, covers can be
          placed over drainage channels, trenches, and other drains in
          graving docks to prevent entry of abrasive blasting debris.

BMP 6.    Segregation of Waste Water Flows in Drydocks..   The  various
          process wastewater streams shall be segregated from sanitary
          wastes.   Gate  and  hydrostatic  leakage  may  also require
          segregation.

BMP 7.    Contact Between Water and  Debris.   Shipboard  cooling  and
          process  water  shall  be directed so as to minimize contact
          with spent abrasive and paint and other debris.  Contact  of
          spent  abrasive  and paint by water can be reduced by proper
          segregation and control of wastewater streams,.  When  debris
          is  present,  hosing  of the dock should be minimized.  When
          hosing is used as  a  removal  method,  appropriate  methods
          should  be incorporated to prevent accumulation of debris in
          drainage systems and to promptly remove it from such systems
          to prevent its discharge with wastewater.

BMP 8.    Maintenance of Gate Seals and Closure.  Leakage through  the
          gate  shall  be  minimized  by repair and maintenance of the
          sealing  surfaces  and   proper   seating   of   the   gate.
          Appropriate  channelling  of  leakage  water to the drainage
          system should be  accomplished  in  a  manner  that  reduces
          contact with debris.

BMP 9.    Maintenance of Hoses,  Soil  Chutes,  and  Piping.   Leaking
          connections, -valves, pipes, hoses, and soil chutes carrying
          either water or wastewater shall  be  replaced  or  repaired
          immediately.   Soil chute and hose connections to the vessel
          and to receiving lines or containers shall be  positive  and
          as leak free as practicable.

BMP 10.   Water  Blasting,  Hvdroblasting,  and  Water-Cone   Abrasive
          Blasting     (Graving    Docks).     When   water   blasting,
          hydroblasting, or water-cone blasting  is  used  in  graving
          docks to remove paint from surfaces, the resulting water and

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          debris  shall  be  collected  in  a  sump  or other suitable
          device.  This mixture  then  will  be  either  delivered  to
          appropriate containers for removal and disposal or subjected
          to  treatment  to  concentrate  the  solids for disposal and
          prepare the water for reuse or discharge.

CURRENT TREATMENT AND CONTROL TECHNOLOGIES

Most of the current efforts toward water  pollution  control  in  both
graving   docks   and   floating   drydocks   are   derived  from  the
recommendations of the rationale  for  shipbuilding  and  ship  repair
facilities  published  by  the  Denver  branch of EPA's National Field
Investigations Center in 1974,  (Reference  2),  after  observing  the
practices  in  effect in some shipyards.  That document emphasized the
segregation of wastewaters and general housekeeping practices.  It was
recommended  that  all  water  flows  be  intercepted   or   otherwise
controlled  in  order to prevent contact with spent paint and abrasive
and other solid  materials  on  the  drydock  floor.   Procedures  for
handling  particular  water  flows,  cooling water, hydrostatic relief
water,  gate  leakage,  and  air  scrubber   water   were   specified.
Miscellaneous  trash was to be eliminated through "the diligent use of
waste receptacles or a thorough clean up...prior to  flooding."  Clean
up  of  the  drydock  floor  to "broom clean conditions" prior to each
undocking was recommended.

Many of the shipyards contacted or visited during the course  of  this
study  have  made efforts to comply with these recommendations.  Their
efforts fall into two general areas (as set forth in Table VII-1):


     o    Clean up of abrasive

     o    Control of wastewater flows

The extent to which particular treatment and control technologies were
found to exist during the contact and visit phase of  this  study  are
shown in Table VII-2.

The  following  paragraphs  describe observed sequences of the drydock
treatment and control technologies listed in Table VII-3.   It  should
be noted that certain of these processes and technologies are designed
to  reduce  or  eliminate  effluents  in  drainage pump discharges and
overboard flows from floating drydocks.  Others are effective  on  the
much larger discharges which occur during deflooding and sinking.  The
next  few pages document procedures for the clean-up of spent abrasive
and other solid drydock debris at seven shipyards which  were  visited
and observed (labeled shipyards A through G)  as well as procedures for
handling cooling water discharges.
                                 85

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                         Table VII-1.  WATER QUALITY TREATMENT ANC CONTPOL
                           TECHNOLOGIES CURRENTLY BEING USED IN DRYDOCKS
    Purpose

Clean-up of Abrasive
 From Drydock Floor

 From Drainage Trenches
Control of Wastewater
 Flows
                             Technology
Front Loader
Hand Shovel and Broom
Eackhoe
Hand Shovel

sill. Channeling, or
 Trench Drain for
 Control of Gate Leakage
 and Hydrostatic Relief
                                                           Pollutants Possibly
                                                                Affected	 Applicability
FLO, SUS, SET, HM
FLO, SUS, SET, HM
FLO, SUS, SET, HM
FLO, SUS, SET, HM
                                                           FLO, SUS, SET, HM, O
GD, FD
GD, FD
GD
GD
FLO « Floating  Solids
SUS = Suspended solids
SET * 5ett.l€able  Solids
O * Oil  and Grease
HM «  Heavy Metals and Other Chemical  Constituents
                                   pH = pH
                                   Air = particulates
                                   SOLIDS -  Solid waste
                                   GD = Gravinq Dock
                                   FD = Floating Drydock
                                              86

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                         Table VII-2.  WATER QUALITY TREATMENT AND CONTROL
                    TECHNOLOGIES UNDER DEVEtOPMENT CR NOT B.EING USED IN DRYDOCKS
Purpose
                        Technology
Clean-up of Abrasive
 From Drydock Floor     Mechanical Sweeper
 From Drydock Floor     Vacuuir Recovery
  or Drainage Trenches  Equipment  (Sta-
                         ipnary or Mobile)
Alternative To
 Conventional Dry

Abrasive Blasting
control of Wastewater
 Flows
                       Water Cone Abrasive
                        Blasting

                       Wet Abrasive Blasting
                       Hydroblasting  (Steady
                       Streair or Cavitation)
                       Closed-Cycle Abrasive
                        Blast and Recovery
                       Cyclone Separation
                        and Cheirical-Physical
                         Pretreatirent

                       Channeling for Improved
                        Fleer Crainaqe
                       Curbing 6 Channeling
                        on Floating Drydccks
                       Scrupper Boxes,  Hose,
                        Piping, and/cr  Pumps
                        for Clean Water
                        Discharges
                       Cover Plates to  Prevent
                        Abrasive frcir Entering
                        Drainage System
                       Containment, cf Flews
                        frcir Wet Blasting

                       Baffle Arrangement  for
                        settling in the Drainage
                        System
                       Contained Absorbent
                        in Discharge  Flew  Path
                       wire Wesh in Discharge
                        Flew Path
                       Adaptation  of  Pcntccns
                        for Settling  Solids

                       Flat Floor  Overlay
                       Removal  of  Bilge
                        Block  Slides
                       Increased Keel Blcck
                       Clearance
                       Hydraulic Bilge Blocks

  i; =  Sewage            O = Oil and  Grease
rLO =  Floating Solids  HM = Heavy  Metals and
3US =  Suspended Solids      Other  Constituents
3FT =  Settleable Solids pH =  pH
Treatment  of Waste-
 water  Flows
 Access  for Clean-up
  Operations,
                                                     Pollutants Intended
                                                     To Be Affected	
FLOW, SET, SOS, HM


FLO, SET, SDS, HM


       MR

       AIR
Applicability


  GD, *»


  GD, FD


  GD, FD

  GD, FD
AIR, SET, SUS, HM, SOLIDS  GD, FD

AIR, SET, SUS, HM, SOLIDS  GD, FD

AIR, SET, SUS, HM, SCLIDS  GD, FD
pH



SET, SUS, HM, O            GD

SET, SUS, HM, O            FD



SET, SUS, HM, O            GD, FD


SET, SUS, HM               GD

SET, SUS, HM, O           . GD, FD

SET, SUS                   GD


O                          GD

FLO                       GD

SET, SUS, O               FD


FLOW,  SET,  SUS,  HM        GD, FD

FLO, SFT, SUS, HM         GD, FD
FLO, SET, SUS, HM         GD, FD
FLO, SET, SUS, HM         GD, FD
FLO, SET, SUS, HM         GD, FD

    AIR = Particulates
    GD = Graving Docks '
    FD = Floating Drydocks
SCLIDS = Solid Waste
                                              87

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   '.Cable VII-3.  REPORTED APPLICATION OF THE TREATMENT AND CONTROL TECHNOLOGIES

                                        Shipyards Visited
Purpose
Clcan-Up of
Abrasive From
DrydocX Floor


From Drainage
Ditches


Alternative to
Conventional Dry
Abrasive Blasting









Control of Waste-
water flows
Technology
Front Loader
Mechanical Sweeper
Hand Shovel
Broom
Vacuum Recovery Equipment
Backhoe
Hand Shovel
Vacuum Recovery Equipment
Container Lifted by Crane
Water Cone Abrasive
Blasting

Wet Abrasive Blasting
Hydroblasting
Steady Stream
Cavitation
Closed Cycle Abrasive
Blast and Recovery
Cyclone Separation
Chemical-Physical
Pretreatment
Sill/ Channeling/ or Trench
Drain for Control of Gate
A


X

X
X
X
*
X
X
X


X

X
X
X

X



B


X

X
X
X
*
X
X
X


X

X
X
X

X



C


*

X
X
NA
NA
NA
NA
X


X

X
X
X

X



D


X

*
Z
X
*'
Z
X
*


*

X
X
Z

X



E


*

*
X
X
*
X
X
X


*

X
X
X

Z



F
X
X
X
X
X
*
*
X
*
X


X

X
X
X

X



G
*
X
*
X
X
NA
NA
NA
NA
X


X

X
X
Z

X


NA
Leakage and Hydrostatic Relief











Treatment of
Wastcwater Flows







Channeling for Improved
Floor Drainage
Curbing and Channeling of
Floating Drydocks
Scupper Boxes/ Hose/ Piping/
and Pumps for Clean Water
Discharges
Cover Plates to Prevent
Abrasive from Entering
Drainage System
Containment of Floor from
Wet Blasting
Baffle Arrangement for
Settling in the Drainage
System
Contained Absorbent in
Drainage Discharge Flow Path
Wire Mesh in Drainage
Discharge Flow Path
Adaptation of Pontoons for
Settling Solids
X

X



X


X

X


X

X

X

X

NA



X


NA

Z


X

X

NA

X

X



NA


NA

NA


NA

NA

X

*

X



X


X

X


X

X

X

X

NA



*


*

X


X

NA

NA

X

NA

X

X


X

X

X

NA


NA NA

X




NA

NA


NA


NA

NA

X

                                                                 Shipyards Contacted (H Through AI
                                                                                     Insufficient
                                                                 Use  Do Not Use     Information
                                                                 21
                                                                  1
                                                                 26
                                                                  5
                                                                  2

                                                                  0
                                                                  0
                                                                  0
                                                                  0

                                                                  0


                                                                  0

                                                                  3
                                                                  0
                                                                  1
 7
27
 1
20
26

.,0
 0
 0
 0
 4
 0
28
 2
 2
 3
 5
 2

30
30
30
30

30
26

23
30
 1

30
                                                                                         30


                                                                                         30

                                                                                         30

                                                                                         21


                                                                                         30


                                                                                         30


                                                                                         30


                                                                                         30

                                                                                         30

                                                                                         30
    Use
X - Do Not Use
2 » Planned/ Infrequent Use, or Under Development
NA- Not Applicable
                                              88

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Most  of  the  facilities  visited  perform  a manual pick up of large
debris prior to each undocking.  Such  debris  includes  scrap  metal,
large  wood  chips or blocks, metal cans, scrap paper, paint cans,  and
the like.  After this manual pick up, with the  aid  of  shovels,  the
debris  is deposited into receptacles on the drydock floor for removal
and disposal.  Some shipyards require this procedure  at  the  end  of
each  shift.   Upon  completion of this phase, only spent abrasive and
other small sized debris remain on the drydock floor.   A  variety  of
procedures  and  technologies  to remove the remaining substances were
observed.

At many shipyards, no efforts are made to remove spent  abrasive  from
the  drydock  floor  prior  to  flooding.  Docks servicing fresh water
vessels rarely do any extensive blasting and consequently do not  have
spent  abrasive to collect.  In some cases contractual requirements do
not allow time for clean  up.  Some  companies  regard  the  clean  up
process  as  difficult,  time-consuming,  labor-intensive,  and  hence
expensive.  The practice of no clean up was  observed  in  smaller  or
older  drydocks, particularly those with raised bilge block slides and
those not requiring keel or bilge block movement  prior  to  the  next
docking.   The necessity for clean up is perceived at these docks only
when accumulations  of  spent  abrasive  reach  such  levels  that  it
interferes  with  keel  or  bilge block placement or movement, creates
hazardous  working  conditions,  or   reduces   productivity.    Those
conditions may be reached after only a few ships have been serviced or
after many.  Clean up may be as frequent as weekly or as infrequent as
semiannually.

When  clean  up  is necessary, front loaders are usually placed on the
drydock floor.  With graving docks, cranes are required to  lower  the
machinery  into the dock basin.  The front loader is often modified to
permit access to the floor beneath the ships hull and consequently  to
operate  while the ship is still in dock.  The loaders scrape and push
the spent abrasive into piles.  Men with shovels and the front loaders
then place the accumulated waste in containers or hoppers.

When bilge block slides are present or low keel blocks  are  employed,
the  efficiency  of operation of the front loaders is greatly reduced.
The equipment has difficulty  in  passing  over  bilge  block  slides.
Frequent  stopping  and  starting, climbing and falling wears down the
equipment and is time consuming.  Laborers with shovels must  manually
clean  areas inacessible to the front loader, such as beneath the hull
and around the blocks and slides.

To remove the remaining  grit  some  shipyards  use  manual  sweepers.
Workers  with  push  brooms  sweep  the  abrasive into piles which are
transferred to the hoppers.
                                 89

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In a few instances mechanical sweepers are also used.,  One sweeper,  a
modified  1-3/4  ton  truck,  employs  horizontal  and vertical rotary
brushes to loosen and pick up spent abrasive and other debris from the
floor.  These wastes are collected inside the  sweeper.   The  sweeper
can make two passes along the length of the dock before becoming full;
then  it  must  be  emptied  before continuing.  The sweeper dumps its
contents in a pile on the floor of the  drydock.   The  pile  is  then
loaded into containers by front loaders and laborers with shovels.  --
                                                                 *.,'.* > * -f*V
The  mechanical  sweeper  has  no  arrangements for reaching around or
under obstructions.  It is also too high to clean under ships and  can
only  clean  those  areas  over  which  it passes.  The sweeper cannot
operate  effectively  unless  the  floor   is   clear   of   removable
obstructions  such as scupper hoses, hoppers of abrasive, scaffolding,
and materials being used in the drydock   (paint  cans,  metal  plates,
etc.).  Thus, the sweeper does not begin clean up until after exterior
work  on  the  hull  has  been  completed.  When a large ship has been
docked, there is little clearance along the sides or at the end of the
dock.  In such cases, space does not allow for the sweeper to be  used
prior to undocking.                                             • ••"'"'-"•'

Shipyard  A  has  two  graving  docks  and  three floating drydocks It
utilizes scupper boxes and hoses to direct  cooling  water  discharges
from  the  vessel  to the drydock drains and ultimately to the harbor.
Graving dock caisson leaks are intercepted at the outboard end of  the
dock  and  pumped  back to the harbor without coming into contact with
solid wastes on the floor of the  graving  dock.  Hydrostatic  leakage
flows  to  drainage  trenches  along the periphery of the floor and is
pumped to the harbor.  The wastes are invariably wet and  packed  from
flooding  or sinking of the dock, from rain, and from the movement and
placement of equipment, men and materials.   This  makes  the  drydock
floor  at  Shipyard A difficult to clean thoroughly.  Also, Shipyard A
drydocks have bilge block  slides  that  are  raised  above  the  dock
surface and interfere with cleaning operations.
Clean  up  occurs  whenever  abrasive buildup has reached a depth such
that the bilge blocks can no  longer  be  repositioned  on  the  bilge
slides.  This is necessary following approximately five dockings. When
clean  up  is  necessary,  front  loaders  are brought in to scoop and
scrape the drydock floor.   Wastes  are  accumulated  in  piles,  then
collected   in  containers  using   front  loaders  and  shovels.   The
containers are lifted out of the drydock by cranes and placed onto  or
emptied  into  trucks.  Laborers with hand shovels accompany the front
loaders, primarily under the hull and at the bilge  blocks  and  their
slides.                                                            -

Shipyard  B  has  five  graving docks and cleans up spent abrasive and
related debris prior to each undocking.  The  clean  up  procedure  of
Shipyard  B  is  identical  to  that  of  Shipyard A except that it is
                                  90

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performed more frequently.  As  the  time  for  undocking  approaches,
front  loaders and laborers with shovels clean the floor.  In Shipyard
B, the wastes are frequently dry.  Shipyard  B  has  no  raised  bilge
block  slides.   Thus,  the  clean up at Shipyard B is ordinarily less
time consuming per  occurrence  than  the  clean  up  at  Shipyard  A.
Shipyard  B  uses  scupper  boxes  and  hoses  to direct cooling water
discharges to the drydock drains.  The hoses observed,  however,  were
in  poor  shape  and  considerable  leakage  flowed across the drydock
floor.  The discharges are pumped  from  the  drains  to  the  .harbor.
Caisson  leakage  is  intercepted at the outboard end of the docks and
pumped to the harbor.  Hydrostatic relief and leakage waters  flow  to
trenches along the periphery of the dock and are pumped to the harbor.

Shipyard  C  has  two  flush  decked floating drydocks and also cleans
prior to and after each undocking.  The cleaning is performed using  a
mechanical  sweeper  and a front loader.  The sweeper and front loader
are  utilized  to  clean  as  best  as  practicable  before  flooding.
Following  flooding and undocking of the vessel, the sweeper and front
loader are returned to the dock and work  unimpeded  (except  for  the
keel   blocks  and  bilge  blocks)  and  effect  a  complete  cleaning
operation.   In  every  case,  the  sweeper  completes  its  clean  up
including   areas  previously  inaccessible  subsequent  to  flooding,
undocking, and deflooding but before the docking of the next vessel.

Shipyard D has three graving docks and two floating  drydocks.   Clean
up  of  spent  abrasive  and  associated  debris  is  performed  on  a
continuing basis.  Upon completion  of  a  blasting  operation,  front
loaders  and  shovels  are brought in to collect the wastes into piles
and then load them into containers.  This operation may occur  several
times  during a single docking depending on the scheduling of abrasive
blasting.  Following the use of front loaders  and  shovels,  laborers
use  push brooms to sweep the docks.  Just before undocking, the front
loaders, shovels, and brooms are returned to the drydock floor  for  a
final comprehensive clean up.  On occasion, remaining wastes are hosed
to  the  drainage system.  The drainage system and the flooding tunnel
are shovelled out on an as-required basis, but not  necessarily  prior
to each undocking.  Scupper boxes arid hoses are attached to the vessel
in  drydock  to  direct  cooling  waters  to drains discharging to the
harbor.  Hydrostatic  leakage  water  and  water  from  internal  tank
blasting units flow across the drydock floor to overboard drains where
they are pumped to the harbor.

Shipyard  E  has  one  graving dock. The clean up at Shipyard E begins
with front loaders and shovels.  The shovellers  accompany  the  front
loaders  in  addition to cleaning those areas the front loaders cannot
reach or cannot clean effectively, such as at corners and surfaces  or
between bilge blocks.  Wastes are consolidated into piles before being
loaded  into  containers.   A  mechanical  sweeper  follows  the front
loaders and shovels.  The sweeper works like the sweeper  at  Shipyard
                                 91

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C«   If  these  procedures  do  not  result  in  a  satisfactory floor
condition, shovels and push brooms  are  used  to  complete  the  job.
Flooding  ports  in  the  dock  floor  are shovelled out prior to each
undocking.  The flooding tunnel is  inspected  and  shovelled  out  if
necessary.   Stairways  are swept manually, as are the utility dugouts
and the altar.  Areas adjacent to the dock are  cleaned  by  a  small,
mobile,  mechanical  sweeper  the  size  of  a small front loader.  No
hosing of abrasive is performed at Shipyard  E  during  the  clean  up
prior  to  undocking.  Clean up of abrasive and debris occurs for each
ship at the end of its stay in the drydock, not on an ongoing basis as
is the practice at Shipyard D.  Scupper boxes and hoses  are  attached
to  the  vessel after drydocking to direct cooling water discharges to
drains to the harbor.  The graving dock was dry with  no  evidence  of
hydrostatic  relief  or  leakage water in the dock during the visit to
this shipyard.                               '    =.,^-. .

All of the shipyards described up  to  this  point  service  primarily
saltwater  ships which require high levels of abrasive blasting.  Some
shipyards service only  freshwater  ships.   Clean-up  procedures  and
technologies at these yards are correspondingly different.

Shipyard  F  has  two  graving docks and services vessels that sail in
fresh  (inland)  waters.   This  facility  does  very  little  abrasive
blasting.   Ships  at this yard receive no abrasive blast treatment at
all to remove paints.  Shipyard F has no mechanized equipment for  the
removal  of  spent  abrasive and other granular debris. It performs no
clean up of such materials prior to undocking.  Large debris is picked
up  manually.   After  flooding,   undocking,   and   the   subsequent
deflooding,  material  accumulated on the drydock floor (which at this
point includes silt and other debris which entered during flooding) is
hosed to the drainage trenches.  Hosing of the dock floor  is  carried
out  in  order  to  maintain  clean  working conditions and to improve
productivity.   Therefore,  the  clean  up  is  not  always  complete,
especially  at  the  ends  of the dock, near the drainage trenches and
away from working or dock entry areas.  Little hosing is done on minor
accumulations around the keel blocks  or  bilge  blocks  if  no  block
movement  is necessary.  Periodically (every few months), the trenches
fill and require cleaning.  All drainage water from the graving  docks
is  pumped  into a sluice.  A floating box containing an absorbent for
oil and grease completely blocks the  discharge  end  of  the  sluice.
Water  can flow under  (the box extends only a short distance below the
surface) and through the box, but floating oil and grease are  removed
by the absorbent.

All   vessels   are   evacuated   and  shut  down  during  drydocking;
consequently, little or no water of any  type  is  discharged  to  the
graving   docks  during  the  servicing  period.   Caisson  leaks  and
hydrostatic relief or leakage waters are  collected   in  trenches  and
pumped through the sluice to the harbor.
                                  92

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Shipyard  G  has  two floating drydocks.  During ship repair on one of
the  floating  drydocks  (a  flush  deck  dock),  spent  abrasive   is
consolidated  into  piles  using front loaders and shovels.  The piles
are loaded into containers for disposal.  This  activity  begins  soon
after abrasive blast operations have ended regardless of the remaining
period  for  the  ship  to  be in dock.  Shipyard 6 does more abrasive
blasting than Shipyard F, but  rarely  at  levels  comparable  to  the
saltwater  shipyards  A,  B, C, D, and E.  Normally, the crew does not
remain on board during drydocking  at  Shipyard  G.   Since  shipboard
services  are shut down there are no cooling water discharges. -On the
second floating drydock  (having bilge block  slides  on  deck),  spent
paint  and  abrasive  is  cleaned up only when accumulations interfere
with vessel repair operations or cause safety  hazards.   This  occurs
about  twice  a  year.   The  vessel  is  evacuated during drydocking;
consequently, there are no discharges from the ship.

CONTROL AND TREATMENT OF WASTEWATER FLOWS

In addition to clean up  of  solid  wastes  from  the  drydock  floor,
efforts  to control and treat wastewater flows are being undertaken at
many facilities.  In the dewatered graving dock there are two  streams
of  wastewater during ship repair operations:   (1) cooling and process
wastewater discharges, and  (2) flows  from  various  sources  such  as
caisson  leaks,  hydrostatic  relief  or  leakage,  and  industrial or
process wastewater.  Floating drydocks also  have  these  wastewaters,
with   the  exception  of  caisson  and  hydrostatic  leaks.   Process
wastewaters include discharges from air scrubbers, wet grit  blasting,
and  tank  and bilge cleaning.  Tank and bilge cleaning wastes are oil
and water mixtures.  A collection and holding tank system, usually the
Wheeler (TM) type, is used to remove and separate this  waste.   Other
wastewaters  may  be  directed  by hoses or allowed to flow across the
floor into the graving dock drainage system, or  directly  to  ambient
waters from floating drydock pontoon decks.  Miscellaneous water flows
come  from  such  sources  as  hydrostatic relief, non-contact cooling
discharges, gate leakage, and pipe and fitting leakage.  Existing dock
drainage system designs allow process wastewaters to  mix  with  other
wastewater.   They  may  contact  solid  wastes  on the deck or in the
trench before being discharged into ambient waters.                   -

The volume of wastewater discharged from a ship in drydock may  depend
upon  the  point  in  the docking cycle.  As shipboard equipment which
uses water is  being  shut  down  following  docking,  the  volume  of
discharge decreases.  The continuing volume of discharge from the ship
will  depend  upon  the  size  of the crew remaining on board while in
drydock.  Some ship operators, such as the U.S. Navy, keep most of the
operating crew on board  even  when  the  ship  is  drydocked  for  an
extended  period.   This  practice  generates  considerable volumes of
wastewater.  Other operators may shut down all  equipment  and  remove
the entire crew even for short drydocking periods.
                                 93

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Another  factor  bearing  on  the  volume  of  water passing through a
drydock is the effectiveness and level of maintenance  effort  applied
by  shipyard facility personnel to the many fittings and valves in the
drydock potable and nonpotable water systems.  Industrial water  usage
is minimal and higher flows occur only if wet abrasive blasting, water
cone  blasting,  or hydroblasting is used.  The use of hoses for clean
up also contributes to wastewater volume.  Drydock  industrial  waters
are  sometimes  controlled  by channels, sills, and drainage trenches.
Some graving  docks  have  arrangements  for  interctjpting  flows  and
conducting  the  water  to  drainage systems.  This reduces contact of
gate leakage and hydrostatic relief water solids on the drydock floor.
Floating drydocks, on the other hand, generally lack arrangements  for
the containment of flows, and have no hydrostatic or gate leakage.

Graving  dock  drainage  system  designs  vary  widely but all involve
networks of gutters, trenches, and/or culverts which serve to  collect
the  heavier  settleable  solids  transported in industrial wastewater
flows.  Unless promptly removed this debris may come in  contact  with
water flows.  To protect drainage pumps from excessive wear or damage,
some  drainage systems are designed with settling basins or sand traps
to intercept and settle even  the  lighter  particles.   This  removes
transported particles from the discharge flow but may increase contact
of water with solid wastes.  Some of these settling locations, such as
shallow  transverse  and longitudinal gutters in the drydock floor are
relatively easy to clean out.  Large  longitudinal  drainage  culverts
under the walls of graving docks can be extremely difficult to clean.

TREATMENT  AND CONTROL TECHNOLOGIES UNDER DEVELOPMENT OR NOT IN COMMON
USE

Many technologies are being  developed  that  potentially  can  reduce
solid  waste,  expedite  clean up and control wastewater flows. In the
section on "Control or Clean Up of Abrasive Through Access In Clean Up
Operations11 these technologies are discussed. The second half of Table
VII-1 has summarized these developmental projects-

Control or Clean Up of Abrasive

High-suction vacuum grit removal equipment,  such  as  the  Vacu-Veyor
 (TM)  unit,  is  used  extensively  to  collect and remove debris from
blasting operations in the ship*s  interior.   Occasionally,  however,
the  situation  accommodates  placing  a container directly beneath an
access hole cut  through  the  ship's  side,  to  collect  the  debris
directly.    Several  existing  kinds  of  equipment,  not  originally
designed  for  drydock  use,  are  being  evaluated  and  modified  to
facilitate  the removal of spent abrasive and debris.  Vacu-Veyor  (TM)
units are relatively simple devices which are  used  in  removing  dry
abrasive  and  debris  from   internal  tank  blasting  operations  and
occasionally from drydock floors.  They suffer, however, from   a  lack

-------
of   mobility   and   the  airborne  particulate  material  cannot  be
effectively contained when blown into open skip boxes  (Reference  9).
At  least  one  shipyard  is  attempting  to develop this equipment by
enclosing the container and making the unit more easily moveable.  Two
other complex, high-suction vacuum machines are  being  evaluated  and
developed   by   shipyard  facilities.   They  are  the  VAC-ALL  (TM)
(References 8r 9, & 12) and the VACTOR 700 (TM)  (References  6  &  8)
units.  Both of these units have demonstrated tremendous capability to
move  large  amounts  of  grit in a relatively short time but both, in
their  present  configuration,  have  many  limitations  for   drydock
application.  A third type of vacuum equipment being evaluated for use
in removing grit and debris from drydock floors is a low profile self-
propelled  device called the ULTRA-VAC (TM) Grit.Vacuum.  It shows the
most  promise for application in flush floored drydocks and  can  best
be  described as a powerful vacuum cleaner on wheels (References 8, 9,
& 12).  Until a design evolves from the  development  of  these  three
types  of  vacuum  equipment  that  will meet the needs of the varying
drydock characteristics, most facilities will be forced to  resort  to
labor intensive, time consuming techniques to remove debris.

Alternatives  to conventional dry abrasive blasting include water cone
abrasive blasting, wet abrasive blasting, hydroblasting (steady stream
or cavitation), and closed cycle abrasive blast and recovery.  Some of
these techniques  have  potential  for  reducing  or  eliminating  the
quantity  of  solids  required in blasting but some substitute a water
pollution problem  for  an  air  pollution  problem.   None  of  these
technologies can completely replace conventional dry abrasive blasting
and  all  are in various stages of development..  Table VII-2 indicates
which shipyards contacted are currently practicing these alternatives.

A variation of the wet grit method of abrasive blasting* called  water
cone,  water  envelopment,  or  water  ring, is fairly new but rapidly
gaining popularity  particularly  with  increasing  use  of  organotin
antifouling  paints  on some Navy ships-  This process projects a cone
of water around the stream of air and abrasive as it leaves  the  hose
nozzle.   This  is accomplished by a simple water ring accessory which
fits around any standard blasting hose nozzle.  This  method  has  the
advantages  of  dry  grit blasting with less dust production. It does,
however,  add  to  the  volume  of  industrial  wastewater  and   rust
inhibitors,  when  added, are present in the wastewaters (References 7
and 9) .

Hydroblasting is a surface preparation  method  used  when  extensive,
heavy  abrading  is  not a requirement.  In one technique a cavitating
water jet is used as the abrading material.  As explained in Reference
13:

     "The basic concept simply consists  of  inducing  the  growth  of
     vapor-filled  cavities  within  a  relatively low velocity liquid
                                 95

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     jet.  By proper adjustment of the distance between the nozzle and
     the surface to be fragmented, these  cavities  are  permitted  to
     grow  from  the  point of formation, and then ibo collapse on that
     surface in the high pressure  stagnation  region  where  the  jet
     impacts  the  solid  material.   Because  the  collapse energy is
     concentrated over many, very small areas at  collapse,  extremely
     high,   very   localized   stresses  are  produced.   This  local
     amplification of pressure provides the cavitating water jet  with
     a  great  advantage over a steady non-cavitatiing jet operating at
     the same pump pressure and flow rate."
                                         ,'•'• - vs. j**» •
Considerable success in laboratory  experiments  is  claimed  for  the
CAVIJET  (TM) method but results of field evaluation are not available.

Several  versions  of  closed-cycle vacuum abrasive blasting equipment
are undergoing engineering development and operational  evaluation  at
various  shipyard  facilities.   They  all operate on the principle of
automatically recovering and reusing abrasives. Abraded  coatings  and
fouling  are sometimes separated and contained for land disposal.  The
machines, when operating as designed, are expected to  eliminate  both
air  and  water  pollution  problems resulting from dust emissions and
from solid wastes entering the drydock drainage system.  If steel shot
is used as the abrasive and is recovered,  the  solid  waste  load  is
reduced  many  times.  Steel shot retains its cutting power even after
repeated reuse.  The closed-cycle blaster has limits  however.   These
machines  will  not  completely  supplant  other  surface  preparation
techniques since they are large, heavy, and require considerable space
for maneuvering.  In addition, they are not designed  to  function  on
other  than  nearly  flat  or  gently curving surfaces.  More detailed
information regarding come of these machines is provided in  technical
references to this document, particularly those prepared by or for the
U.S. Navy.

Control of Wastewater Flow            !i  «>

The  control  and  treatment of wastewater flows is critically tied to
the segregation  of  wastewater  streams.   This  philosophy  is  best
expressed in a quote from Reference 6:

     "The key to cessation of unnecessary liquid waste generation...is
     seen  as  segregation  of  wastes  as  completely as possible and
     reasonable.   Unpolluted  waters  should   be   segregated   from
     contaminated solid wastes and vice versa.

     An  appropriate system to collect and convey liquid waste must be
     capable of maintaining segregation until contaminated wastes  are
     removed  from  the  drydock  and  unpolluted  wastes are properly
     discharged to harbor receiving waters."
                                  96

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This report proceeds with definitions of  systems  and  techniques  to
segregate,  collect,  and  transfer  contaminated  and  uncontaminated
wastewater  streams   (and   materials   causing   contamination)    to
environmentally acceptable treatment systems.

A similar philosophy of approach was reported in Reference 11;

     "A  practical  solution to eliminate the large volume of polluted
     wastewater discharge into the  harbor  would  be  segregation  of
     clean  water  flows  from  both  spent  abrasive  and any already
     polluted wastewaters.   This  is  the  basis  for  the  following
     recommendations.   wastewaters can be divided into three streams.
     The first stream, comprised of hydrostatic water, ships*  cooling
     water,   and   miscellaneous   other   equipment   cooling  water
     discharges, could be collected in what will be henceforth  called
     the  clean  water  conduit.   These  unpolluted  waters  could be
     discharged directly  into  the  harbor  without  treatment.   The
     second  stream,  comprised  of  drydock  sanitary  wastewater and
     ships* non-oily wastewater, could  be  collected  in  a  sanitary
     sewer  and  pumped  to  a  municipal sewage treatment plant.  The
     third  stream,   comprising  all  other   wastewater   discharges
     including   ships1   oily  wastewater,  dock  floor  wash  water,
     miscellaneous equipment washings, spills, sewer leaks, rain,  and
     clean  water which accidentally contacts the dock floor, could be
     collected in an industrial wastewater  sewer  and  pumped  to  an
     industrial wastewater  treatment facility."

The  facility that served as a model for these two studies is planning
the  implementation of the recommended improvements.

Segregation of water flows  is  accomplished  by  physical  isolation.
Collection  can  be  through  either  or both in-floor and above-floor
plumbing  systems.  For example, above-floor systems can be  fabricated
from PVC  piping and attached adjacent to keel blocks.

Treatment of Wastewater Flows

Innovative  controls  will be installed at one shipyard in its  graving
docks  having large  transverse  trenches  or cross  drains   near the
outboard  or  drain end.  Involved  is an arrangement of baffles in the
cross  drain as a means  of  minimizing  the  discharge  of  settleable
solids and floating material.  The baffles  will be installed so  as to
use  the cross drain as a  settling pond.  A baffle acts  as  a  dam  to
establish a  water  level  and hence a retention time for settleable
solids to separate.   Water flowing  over the  top of this baffle  will go
directly  to the drainage  pump.   Upstream  of  this  overflow  dam,   a
second baffle  will  be  installed to  form an underflow dam for  holding
floating  debris, oil, or  other  substances for collection  and ^removal
prior   to flooding  the  drydock.   Both baffles will be removable, and
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provisions will be made to drain  off  the  water  held  behind  them.
Settleable  solids  contained  within the cross trench will be removed
for land disposal.  The baffles will be installed after  the  ship  is
secure in the dock and the initial dewatering has been completed.  The
installation  will  not  minimize  the  contact  of  solids with water
streams, but is expected to .reduce the potential of solids transport.

At one facility (Shipyard F),  graving  dock  discharges,  other  than
dewatering,  are  directed  through  a  flume prior to emission to the
adjacent river.  Across this flume, near the discharge end, a floating
box-like structure is placed in the flume after dewatering.  The  box-
like  structure  holds  a  screen  across  the  surface of the flow to
prevent floating trash and debris from entering ambient waters.  It is
filled with absorbent material which removes oil and grease  from  the
discharge flow.  The absorbent material is replaced as needed.

Access In Clean-Up Operations

Two  items  of  drydock  design  make  efforts  to clean up industrial
wastes, such as abrasive blasting debris, more difficult  and  costly.
They  are the height of keel blocks and the existence of raised slides
across the floor  (or pontoon deck) for movement of bilge blocks.

Almost all existing drydocks have keel block heights  of  3-1/2  to  6
feet.   Older docks tend to have smaller keel blocks.  With short keel
blocks the working space between the drydock deck and ship  bottom  is
too  restricted  for men using shovels and brooms to effectively clean
up blasting debris  and  for  using  mechanized  techniques  currently
available.   This  situation  is  most severe when the ship has a wide
beam and a flat bottom.  At least  one  new  graving  dock,  currently
under construction, will have 10-foot high keel blocks.

Graving  docks  and  floating  drydocks  which have bilge block slides
present a particularly severe problem to clean-up activities.

These solids establish corners and crevices from which fine debris  is
difficult  to  remove.   They  interfere  with the movement of wheeled
equipment and increase maintenance costs  of  the  equipment  used  to
clean   up  blasting  debris   (such  as  small  front  loaders).   The
positioning of these tracks across the flow direction of launch  water
may  be  beneficial,  however,  in  acting as a submerged weir or dam,
trapping sediment that would otherwise wash away.

NON-WATER QUALITY ENVIRONMENTAL ASPECTS

The control and treatment technologies described in this  section  are
designed to improve the water quality of drydock discharges.  However,
some   of   these   technologies  also  impact,  either  favorably  or
                                  98

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unfavorably,  on  other  environmental  concerns,   particularly   air
pollution and solid waste.  This subsection addresses those impacts.

 Air  Pollution   Several control technologies provide alternatives to
conventional dry abrasive blasting.  These  alternatives  include  wet
abrasive   blasting,  hydroblasting  using  either  steady  stream  or
cavitation, water cone abrasive blasting, closed cycle abrasive  blast
and  recovery  equipment, and chemical stripping.  Comparison of these
alternatives must include many  considerations  among  which  are  the
desirability   and  thoroughness  of  surface  preparation,  speed  of
application, labor costs, equipment modifications,  capital  required,
occupational  health and safety, and effects of possible contamination
of water flows.   However,  all  of  the  alternatives  are  extremely
effective  in  the  reduction  or  elimination .of  one  of  the  most
detrimental aspects associated with dry abrasive blasting, namely . the
production of airborne particulates.

Upon  impact,  abrasive particles fracture.  The larger fragments fall
to the drydock floor or occasionally to adjacent land or water  areas.
Smaller  fragments,  however, become airborne or suspended, along with
some particles released from the blasted surface.   Depending  on  the
wind, they may travel appreciable distances.  Shifting to harder blast
media reduces these effects only slightly.

Most  of the technologies listed above have been developed more as air
pollution control measures  than  water  pollution  control  measures..
Closed-cycle  abrasive  blast  and recovery equipment uses a vacuum to
pull blast  particles  from  the  air  as  they  are  released.   This
equipment  (of  which  there  are  several  types in various stages of
development)  is not  totally  successful  in  the  recovery  of  blast
particles;  however,  the  characteristic plume of 3ust emanating from
dry  abrasive  blasting  is  eliminated  and  the  level  of  airborne
particulates   and  suspended  solids  is  drastically  reduced.   Wet
abrasive  blasting  and  water  cone  abrasive  blasting  prevent  the
production  of  airborne  particles  by  wetting blast fragments.  The
moisture-laden fragments then fall to the drydock floor or  drip  down
the  structure being blasted.  Wet abrasive blasting is a particularly
effective means of improving air  quality  in  blasting.   Water  cone
abrasive  blasting,  though  not  as  effective, still reduces the air
pollution problem to a local  one  involving  only  the  blast  nozzle
operator  and those in the immediate vicinity.  Hydroblasting preempts
the problem of abrasive fragmentation by eliminating the source, i.e.,
the abrasive.  Only particles from the surface being blasted  must  be
contended  with and in hydroblasting, these particles are.wet, causing
virtually all  to  drop.   Chemical  stripping  completely  eliminates
airborne  particulates  since  it involves no blasting.  Chemicals are
brushed on, allowed to work, then scraped off manually.  Because slow,
labor-intensive methods are required, chemical stripping is used  very
little.    This   technology   trades  off  particulate  emission  for
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hydrocarbons and other chemical vapors caused by its high  volatility.
Closed-cycle  blasters  under  development  which  use steel shot show
promise of eliminating essentially all air and  water  pollution  from
blasting operations.

Vacuum  material  handling  equipment  can  be a source of particulate
emission where open collection containers are used.  The magnitude  of
this  emission  depends  on the geometry of the collection system, the
volume and rate of material being moved, and the material composition,
particularly  its  moisture  content  and  particle  weight.    Vacuum
equipment   is  ordinarily  diesel  powered  and  thereby  contributes
hydrocarbons, nitrogen oxides, carbon monoxide,  and  other  emissions
associated  with  diesel engine combustion.  Mobile units have greater
fossil fuel energy requirements than stationary units and thus produce
higher levels of air pollution.

A number of the control  technologies  similarly  affect  air  quality
through  requirements  for  power  from  local  combustion  equipment.
Mobile sweepers and front loaders are examples.  Pumping equipment  on
mobile  floating  drydocks are usually diesel powered, so that drydock
design changes which result in the installation of  pumping  equipment
may  add  to  air  emissions.   Such  design changes include modifying
floating drydock pontoons for use as settling tanks, adding filtration
equipment or extensive new piping,  and  other  efforts  to  segregate
wastewater  flows which require additional pumping.  Air emissions may
not increase if the pumping requirements are split without  increasing
input  energy  requirements.   Hydroblasting,  by  avoiding  air  as a
propellant, reduces air emissions from local air compressor  stations.
This  reduction  occurs at the expense of emissions from the alternate
compression source.  The practice of shutting down shipboard equipment
while in drydock also reduces air emissions, in this case, from fossil
fueled equipment on board.

Solid Waste

Conventional dry abrasive blasting creates  appreciable  accumulations
of  solid  waste.   Where  it  is  applicable,  closed-cycle blast and
recovery  equipment  can  greatly  reduce  the  quantity  of  abrasive
required  and  alleviate  the  clean  up  of spent paint and abrasive.
Disposal of the material, whether from open or  closed-cycle  blasting
is  required.   Generally,  solid  wastes  will  be  transported  by a
contractor to landfill disposal sites..  Though the degree to which the
wastes  are  potentially  harmful  has  not  been  assessed,   several
considerations   appear  warranted.   In  order  to  ensure  long-term
protection of the environment from potentially  harmful  constituents,
special  considerations  of  disposal  sites should be made.  Landfill
sites  should  be  selected  which  prevent  horizontal  and  vertical
migration of constituents to ground or surface waters.  In cases  where
geologic  conditions  are not suitable adequate mechanical precautions
                                  100

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 (e.g.,  impervious  liners)  may  be  required  to  ensure   long-term
protection of the environment.  A program of routine periodic sampling
and  analysis  of  leachates may be advisable.  Where appropriate, the
location of solid hazardous materials disposal sites, if  any,  should
be   permanently   recorded   in   the  appropriate  office  of  legal
jurisdiction.

Of particular concern is the disposal of  the  new  organotin  wastes.
These  toxic  compounds which are sometimes used in antifouling paints
may be present in the spent paint, as well as originating  from  paint
spills  and overspray.  Currently the Navy, for example, requires that
these wastes be sealed in drums and  shipped  to  a  properly  managed
landfill.  These precautions are taken to prevent runoff, seepage, and
possibly leaching of organotin compounds.       -

Other Environmental Aspects

In  addition  to  air  pollution  and  solid  waste, some of the water
control and treatment technologies  exhibit  minor  effects  in  other
environmental  areas.   The  shut  down  of shipboard services reduces
cooling water discharges and consequent thermal pollution.   Noise  is
also reduced.  Alternative technologies to dry abrasive blasting which
do  not  employ  air  as  a propellant (hydroblasting and wet abrasive
blasting)  reduce the load on shore-based air compressors and less heat
is added to the water.  Thermal discharges from this source  are  thus
reduced.   Vacuum  material handling equipment and other engine-driven
equipment (closed cycle abrasive blast and recovery equipment,  mobile
sweepers,   front  loaders, etc.)  add to the general noise level in the
drydocks.
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                             SECTION VIII

               COST OF TREATMENT AND CONTROL TECHNOLOGY


INTRODUCTION

The economics of currently applied treatment  and  control  technology
were  obtained during shipyard visits.  The technologies, as listed in
Section VII, include:

     o    Technologies for the clean up of abrasive

     o    Alternatives to conventional dry abrasive blasting

     o    Control technologies for wastewater flows excluding sewage

     o    Treatment technologies for wastewater flows excluding sewage

The costs of clean-up and best  management  practices  were  developed
from  information  obtained  during  visits  to shipyards A through G«
These represent a composite of costs for these seven  facilities,  and
are  not  specific  to any one of them.  This information was obtained
during the period March through May of 1976 and has not been  adjusted
for inflation occurring since that period.

The reported and observed application of these technologies appears in
Table  VII-2.   Clean  up  of  abrasive  is  practiced  at each of the
shipyards visited and has been for many years.  Much cost  information
is  available concerning technology for the clean up of abrasive. With
the exception of scupper boxes and piping, and design features for the
control of gate  leakage  and  hydrostatic  relief  water,  the  other
treatment and control technologies have found little application among
the  shipyards  visited.   Many  of  these  technologies  are  in  the
planning, research, or experimental stages of  development  and  could
not  be  evaluated  with  respect  to economics since actual cost data
(particularly operation and maintenance costs) are  unavailable.   The
cost data applies to current technologies for the clean up of abrasive
as   reported   and   observed  during  the  shipyard  visit  program.
Developmental methods are not considered.

Throughout the history of conventional dry abrasive blasting,  it  has
been necessary for shipyards which use appreciable amounts of abrasive
in  their  docks  to  clean  it  up periodically solely to continue in
business.  Abrasive on the drydock floor can adversely affect  working
conditions and productivity.  It can hamper the placement and movement
of  bilge  blocks.   It  hampers the movement of mechanized equipment.
Consequently, shipyards have performed periodic clean up  of  abrasive
from  the  drydock  floor.   However,  in  1974,  the EPA, through its
                                 103

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National Field Investigations Center in Denver, Colorado,  recommended
that  shipyards  increase  their  efforts  to prevent wastewaters from
contacting abrasive on the drydock floor and to  clean  up  to  "broom
clean" conditions prior to flooding or sinking.

Response  to  EPA's  recommendations  has  been  mixed.   It  is  very
difficult to segregate clean-up costs for  environmental  purposes  at
these  shipyards and those costs which would have been incurred during
the normal course of business.  The  estimated  costs  developed  here
reflect  stepped  up  efforts  to reduce effluent discharges to nearby
water bodies.  But no effort is made to  isolate  the  cost  of  these
stepped  up  efforts.  Costs presented later in this section are total
costs of clean-up operations as currently performed.

The cost data include capital, labor, operating, and maintenance costs
incurred directly during clean-up operations.  Certain indirect  costs
could  not  be  estimated accurately and are not included.  A thorough
clean up of drydock floor space, trenches,  tunnels,  and  altars  can
lead  to increased drydock time per ship.  If such time  is allowed for
in contract arrangements with shipowners, busy shipyard  operators  may
find  that  they  cannot  service  as  many  ships  per  year and must
correspondingly suffer a drop  in  revenue.   If  increased  time  for
clean-up activities is not allowed for, the shipyard is  faced with the
loss  in  revenue or additional charges to the ship owner.  Frequently
at shipyards in this position, complete clean up prior to flooding  is
not performed.  Either way, time delays create dissatisfied customers,
and can harm shipyard reputations and good will as well  as current and
future  business  prospects.  These are important considerations which
can produce hidden costs not recognized as clean-up related.

On the other hand, the clean up of  abrasive  prior  to  flooding  may
provide  some  economic  benefits.   When  abrasive  blasting has been
particularly heavy, collection of the  abrasive  may  be required  to
profitably  carry  out repair operations on a vessel.  Thus, increased
clean-up efforts may provide  benefits  as  well  as  increase   costs.
However,  this section does not present a cost/benefit analysis  of the
operation.  Only those costs are included that  directly result from
the clean-up methods discussed.

IDENTIFICATION  OF  METHODOLOGY  CURRENTLY  USED  IN  BEST  MANAGEMENT
PRACTICES

Best  Management Practices, previously  defined,  arcs  directed   toward
clean up  within  the   dock  working  area  and  control of water and
wastewster flows into and  out of the dock.  Wide differences are found
between  facilities and conditions  in facilities, and  as  a  result  of
these differences.  Best  Management  as practiced at one  dock may be
either inadequate or unnecessarily extensive   if  applied   to   another
dock.
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Any  attempt  to  define  a total cost of Best Management and to apply
this to specific facilities is misleading because of  the  differences
encountered.   A  preferred  approach  to defining cost is to evaluate
costs  of  individual  operations,  which  can  be  applied  in   Best
Management  Practices,  and  normalize these to a standard application
time, or extent.  From such data the costs of Best Management can then
be synthesized  for  individual  docks  depending  upon  the  specific
operations of Best Management required and the time or extent pf these
operations.   This  approach  admittedly  will  not  permit  an  exact
definition of costs because the components going into the values  will
not  account  for  variations  between  facilities,  for example labor
rates.  However, it will be possible to compare the  costs  attributed
to  different  degrees  of  Best  Management  Practices  for any given
facility and to determine combinations of operations which may achieve
equivalent results at reduced expenditures.

Only  costs  associated  with  routine  clean-up  operations  of  Best
Management Practices are considered here.  Costs resulting from events
such  as oil and paint spills are not due to normal operations and are
not incurred on  a  regular  basis.   The  operations  considered,  in
principal,   can  be  applied  in  any  facility  but  all  would  not
necessarily be applied at any given facility.

The cost of segregation and control of water and wastewater  flows  is
not  addressed.  Most such efforts require structural modifications to
the facility.  This  aspect  of  Best  Management  Practices  is  dock
specific.   Differences  in  facility  ages,  construction,  size  and
configuration, and geologic and meteorologic conditions  prohibit  any
valid  effort  to  generalize  with  respect to costs of modifications
needed to achieve water and wastewater segregation and control.

Clean-up operations for which costs are estimated  here  include  both
mechanical  and  manual  techniques.   Mechanical operations use front
loaders,  sweepers,  backhoes,  vacuum  equipment,  and  closed  cycle
blasting.   Worker  use  of  shovels,  brooms,  and  hoses  are manual
operations and in some cases are needed in combination with mechanical
methods.

UNIT COSTS OF BEST MANAGEMENT PRACTICES

The elements of cost which combine to make  up  the  costs  associated
with   Best   Management  Practices  include  capital  investment  and
depreciation, operating and maintenance  costs  for  equipment,  labor
costs    (with   overhead),   and   contract  costs  where  contractual
arrangements are made.  When equipment is used for multiple  purposes,
only  one  of  which  relates  to  the  clean-up  operations, the cost
attributed to management practices must be prorated on  the  basis  of
the fractional time so used.
                                 105

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The  approach  used  in  this  section  has  been  to define the costs
associated with methodologies used for clean  up.   These  costs  have
been  normalized  to  one  eight-hour  shift.   For  comparing various
techniques which may be used in an existing facility, the  unit  costs
per  shift will be multiplied by the number of shifts required for the
cleanup cycle.

Clean-up techniques  and  methodologies  included  in  tM-  breakdown
involve use of front loader, mechanical sweeper, vacuum equipment, and
backhoe  operations.   Labor costs for support of these operations, as
opposed to the direct operation costs, are separately  identified  and
in  most  instances represent manual operations when considered alone..
Disposal costs are estimated on the basis of unit volume.

Table VIII-1 summarizes the clean-up methodologies which may  be  used
to  implement  Best  Management  Practices.  The applicability of each
method is shown.  Where the cost of equipment or method varied due  to
the  presence of raised bilge block slides, two entries have been made
to allow for this effect.  This has been done because  of  the  higher
maintenance  costs  and  life  of  mechanical  equipment  subjected to
operation over raised bilge block  slides.   Under  these  conditions,
depreciation  over  a  three  year  period is used as opposed to eight
years for service in a dock having a smooth floor.

Table VIII-2 shows an estimated  cost  of  solid  waste  removal  from
shipyards.
                                 106

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           Table VIII-2.   COST OF DISPOSAL OF SOLID WASTE
      REMOVED FROM DOCKS  (INCLUDES HAULING AND LANDFILL FEES)
Light
Blasting

Heavy

Notes:

      1.

      2.

      3.

      4.
                Tons of
                 Debris    Volume    Number of
                Per Ship  Cubic Yds  Containers
       200

     1,350
128

862
 8

53
Total Cost
  $ per
Clean Up

 1,000

 6,625
Cost Data as of March to May, 1976.

Bulk Density assumed 116 Ib/cu ft.

Standard container has 16.4 cubic yard volume.

Cost per standard container is $125 for removal
and disposal.
In  using  the  costs  presented  in  Tables  VIII-1  and  VIII-2  the
operations required for best management techniques can be synthesized,,
Where  mechanical  equipment  has  been  defined,  only  the  cost  of
operating  the equipment is included.  Additional costs resulting from
the need for shovellers to work in conjunction with front loaders  (or
for crane operation to move machinery and collected debris to and from
the  dock)  must  be  added  to  define  total cost of each operation.
Finally, these costs are  approximate  and  do  not  reflect  regional
variations,  and  are  based on costs prevailing during the conduct of
this study in 1976.
                                                                     -'•=•4*
COSTS ATTRIBUTED TO BEST MANAGEMENT PRACTICES VS.  ENVIRONMENTAL COSTS
                                                                     , «- .j
Regardless of other considerations  clean  up  of  graving  docks  and
floating  drydocks must be performed at some time simply to permit the
repair and maintenance operations to be carried out.  Some  facilities
may  find  frequent  clean  up  a  necessary  part of their total work
effort, while others may routinely go for long  time  periods  between
clean  up.  Cost of clean up performed as normal maintenance cannot be
considered environmental charges.

Likewise, the cost of implementing a formal Best Management  Practices
program  cannot  be  charged  entirely  to environmental restrictions.
Such a program would be directed toward the management objectives, and
these are primarily for operational purposes.  It is possible that  an
                                 108

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actual cost benefit may be realized as a result of a formal program to
remove  wastes at regular times, but a detailed cost analysis would be
necessary to demonstrate the actual effect.

Only two operations have been identified which, in some instances, may
represent environmental costs:   (1)  implementation  of  a  management
program  requiring  clean  up  at  a frequency in great excess of that
necessary to achieve Best Management Practices, (2) costs incurred  as
a  result  of  special  solids  disposal  methods  required solely for
environmental protection.

In the first of these, only  such  costs  resulting  from  the  excess
practices  imposed  could be related to environmental concern.  In the
more probable case such a program would be adopted at  the  discretion
of  the  facility  management.   Only  where  local regulations may be
stringent enough to force this type of program could  part  of  it  be
attributed to protecting the environment.

The  second  example  is  more  clear  cut.   In  general  contractual
arrangements are in force for ultimate disposal of  abrasive  blasting
debris.   This material most frequently is landfilled.  Many landfills
are regulated to prevent contamination of ground and surface waters by
the materials disposed of in them. Some are not. It may be  necessary,
in certain cases, to alter disposal practices by changing to certified
land  fills  in  order  to  prevent potential damage to groundwater by
leaching constituents from abrasive blasting debris-   In  particular,
the  disposal  of  organotin-based debris has been controlled by Naval
policies which require that  it  be  sealed  in  steel  drums.   Costs
resulting  from  these  practices  may  be  considered environmentally
incurred.

In  summary,  shipyards  which  are  currently  operating  under  Best
Management  Practices  programs  probably  will  experience no adverse
effects in, terms of excessive  costs  or  reduced  operations.   Where
increased  effort  is  necessary  by  other  shipyards to achieve Best
Management Practices, minor effects may be noted.
                                 109

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                              SECTION IX

                           ACKNOWLEDGEMENTS


The Environmental Protection Agency  expresses  appreciation  for  the
support  in  preparing  this  document provided by Hittman Associates,
Inc., Columbia, Maryland, under the overall direction of Mr. -Burton C.
Becker, Vice President, Operations.  Mr. Dwight  B.  Emerson  and  Mr.
Jack  Preston  Overman shared direction of the day-to-day work on  the
project.

Appreciation is extended to the staff of the Environmental Engineering
Department of Hittman Associates  for  their  assistance  during  this
program.  Specifically our thanks to:

     Mr. V. Bruce May, Senior Chemical Engineer
     Ms. Barbara A. White, Manuscript Coordinator
     Mr. Thomas V. Bolan, III, Mechanical Engineer
     Mr. Craig S. Koralek, chemical Engineer
     Mr. Phillip E. Brown, Environmental Engineer
     Mr, J. Patrick Carr, Consultant, 13..B. Navy  (Ret.)

Acknowledgement  and  appreciation  is  given  to  Mr.  Robert Blaser,
Hamilton Standard, Division of United  Technologies  Corporation,  who
made an invaluable contribution to the preparation of this document.

Acknowledgement  and  appreciation  is  also  given  to  Mr.  Harold B.
Coughlin, Chief, Guidelines Implementation Branch, Effluent Guidelines
Division, for administrative support and to Ms.  Kaye Starr, Ms.  Nancy
Zrubek, and Ms. Carol Swann for their tireless and dedicated  effort in
this manuscript.
                                  111

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                              SECTION X

                     REFERENCES AND BIBLOIGRAPHY


                              REFERENCES


1.   Hamilton Standard, Inc., Draft Development Document for  Effluent
     Limitations  Guidelines  and  Standards  of  Performance  for the
     Machinery  £  Mechanical  Products  Manufacturing  Point   Source
     Category, EPA Contract No. 68-01-2914, Washington, DC, June 1975.

2.   U.S.  Environmental  Protection  Agency,  Rationale   for   Water
     Pollution  Control  at  Shipbuilding  and Ship Repair Facilities,
     National Field Investigations Center*  Denver,  Colorado,  August
     1974..

3.   U.S. Department of the Navy, Design Manual-Drydocking Facilities,
     DM-29,  Naval   Facilities   Engineering   Command,   Alexandria,
     Virginia, February 1974.

4.   Automation Industries, Inc., Environmental Impact  Assessment  of
     Floating  Drydocks  Operated by the U.S. Navy, Vitro Laboratories
     Division, Silver Spring, Maryland, May 1975*

5.   Engineering-Science,  Inc.,  Pollutional   Effects   of   Drydock
     Discharges, Berkeley, California, October 1973.

6.   Moffatt & Nichol, Engineers, Industrial Waste and Ship Wastewater
     Collection and Disposal Facility; Drydocks  lf  2,  and  3,  Long
     Beach Naval Shipyard, Long Beach, California, November 1975.

7.   Birnbaum, Bruce, Experimental Grit Blasting of the  U.S.S.  James
     Monroe (SSBN 662) Aboard the U.S.S.  Alamagordo (ARDM 2) at Naval
     Weapons   Station,   Charleston,   South   Carolina,  Naval  Ship
     Engineering Center, Hyattsville, Maryland, October, 1975.

8.   U.S.  Department  of  the  Navy,   Final   Environmental   Impact
     Statement:   Abrasive-Blasting of Naval Ships* Hulls, Washington,
     DC, November 1975.

9.   Ticker, A. and Rodgers, S.,  Abatement  of  Pollution  Caused  by
     Abrasive  Blasting; Status in Naval Shipyards, Report 4549, Naval
     Ship Research and Development Center,  Bethesda,  Maryland,  July
     1975.
                                 113

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10.  U.S.  Department  of   Navy,   "Military   Specification:   Sand,
     Sandblast;  and  Grain,  Abrasive  -  Ship  Hull Blast Cleaning,"
     Military  Specification  MIL-S-22262  (Ships),  Washington,   DC,
     December 4, 1959.

11.  Alig, Craig S., Loner  Beach  Naval  Shipyard  Drvdock  Wastewater
     Discharge Study, Report 4557, Naval Ship Research and Development
     Center, Bethesda, Maryland, December 1975.
                                                " T$ ^"" ' ~
12.  Marks, Earl E., "Report on the Application and Use Experience  of
     the  VAC-ALL  Grit  Removal  Machine," Code  971, Long Beach Naval
     Shipyard, Long Beach, California, 1974.

13.  conn, Andrew F. and Rudy, S. Lee,  Parameters  for  a  Ship  Hull
     Cleaning  System Using the CAVIJETTM Cavitating Water Jet Method,
     Hydronautics, Inc., Laurel, Maryland, July 1975.

14.  Ray, T.B., "Water Pollution  Control  Plant,"  submitted to  the
     State  of  Virginia Water Control Board as a requirement of NPDES
     Permit fVA 4804,  Newport  News  Shipbuilding  and  Drydock  Co.,
     Newport News, Virginia, 1975.

15.  U.S. Environmental Protection Agency.  Draft Report  to  the  San
     Diego  Regional Water Quality Control Board  on Guidelines for the
     Control of Shipyard  Pollutants,  National   Field  Investigations
     Center, Denver, Colorado, July  1,  1974.

16.  Carr, Dodd S.  and  Kronstein,  Max,  "Antifouling  Mechanism  of
     Shipbottom   Finishes,"  Modern Paint  and  Coatings.   Palmerton
     Publishing Co., New York, New York, December 1975, pp.  23-27.

17.  Barry,  Joseph  N.,  "Staff  Report  on   Wastes  Associated  with
     Shipbuilding  and Repair Facilities in San  Diego Bay,"  California
     Regional Water Quality Control Board,   San  Diego  Region,   San
     Diego, California, June  1972.
                                              -•-rib**. .I""
                                  114

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                             BIBLIOGRAPHY


1.   Academy of Natural Sciences of Philadelphia, "Summary of Leaching
     Study for Sun Shipbuilding and Dry  Dock  Company,"  Division  of
     Limnology and Ecology, Philadephia, Pennsylvania, 1974.

2.   Alig, Craig S., Long  Beach  Naval  Shipyard  Drydock  Wastewater
     Discharge Study, Report 4557, Naval Ship Research and Development
     Center, Bethesda, Maryland, December 1975.

3.   Automation Industries, Inc., Environmental Impact  Assessment  of
     Floating  Drydocks  Operated by the U.S. Navy. Vitro Laboratories
     Division, Silver spring, Maryland, May 1975.

4.   Barry,  Joseph  N.,  "Staff  Report  on  Wastes  Associated  With
     Shipbuilding  and Repair Facilities In San Diego Bay," California
     Regional Water Quality  Control  Board,  San  Diego  Region,  San
     Diego^ California, June 1972.

5.   Birnbaum, Bruce, Experimental Grit Blasting of the  u.s.S.  James
     Monroe (SSBN 622) Aboard the U.S.S.  Alamagordo (ARDM 2L at Naval
     Weapons   Station^   Charleston^   South   Carolina,  Naval  Ship
     Engineering Center, Hyattsville, Maryland, October, 1975.

6.   California Air Resources Board,  "Abrasive  Blasting,  Title  17,
     California   Administrative   Code,   Subchapter   6,   State  of
     California, Sacramento, California, February 3, 1976.

7.   California Water Resources Control Board, Water  Quality  Control.
     Plan  for  Ocean  Waters  of  California,  State  of  California,
     Sacramento, California, July 6, 1972,

8.   Chan, D.B. and Saam, Richard D.,  "Drydock  Wastewater  Treatment
     Study,"  U.S.   Navy,  Civil  Engineering Laboratory, Construction.
     Battalion Center, Port Hueneme, California, June 1975.

9.   Conn, Andrew F.  and Rudy, S. Lee,  Parameters  for  a  Ship  Hull
     Cleaning  System Using The CAVIJETTM Cavitating Water Jet Method,
     Hydronautics,  Inc., Laurel, Maryland, July 1975.

10.  Engineering-Science, Inc., Lower James River Basin  Comprehensive
     Water Quality Management Study, Planning Bulletin 217-B, State of
     Virginia Water Control Boad, Richmond, Virginia, July 1974.

11.  Engineering-Science,  Inc.,  Pollutional   Effects   of   Drydock
     Discharges, Berkeley,  California, October 1973.
                                 115

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12.  Hamilton Standard, Inc., Draft Development Document For  Effluent
     Limitations  Guidelines  and  Standards  of  Performance  for the
     Machinery  t>  Mechanical  Products  Manufacturing  Point   source
     Category, EPA Contract No. 68-01-2914, Washington, DC, June 1975.

13.  Huggett, R.J. , Analyses of Sediment and  Elutriate  Samples  from
     the  James River, Virginia, Virginia Institute of Marine Science,
     Gloucester Point, Virginia, July 1975.

14.  Huggett, R.J., Study of  Channel  Sediments;   Baltimore  Harbor,
     Norfolk  Harbor,  York  Entrance  Channel.  Virginia Institute of
     Marine Science, Gloucester Point, Virginia, 1972*

15.  Hurst, W. Calvin and Whiteneck, L.L., An Analysis of  the  Impact
     From   Completion   of   Yard   Modernization,   Todd   Shipyards
     Corporation, Los Angeles Division, San Pedro, California,  Berths
     103-109,  Engineering  Feasibility  Studies,  Inc.,  Los Angeles,
     California, April 1975.

16.  Johnson, Patricia G. and Villa,  Orterio,  Jr.,  Distribution  of
     Metals  In  Baltimore Harbor Sediments, Technical Report 59, U.S.
     Environmental  Protection   Agency,   Annapolis   Field   Office,
     Annapolis, Maryland, 1974.

17.  Marks, Earl E., "Report on the Application and Use Experience  of
     the  VAC-ALL  Grit  Removal  Machine," Code 971,, Long Beach Naval
     Shipyard, Long Beach, California, 1974.

18.  Moffatt & Nichol, Engineers, Industrial Waste and Ship Wastewater
     Collection and Disposal Facility; Drydocks 1, £ and 3, Long Beach
     Naval Shipyard, Long Beach, California, November 1975.

19.  Newport News Shipbuilding and Dry Dock Company,  "EPA  Survey  of
     Wastewater  Discharge  from  Graving  #10  During  the Repair and
     Painting of the SS Claude Conway, May 1975," Laboratory  Services
     Report No. N-5327, Newport News, Virginia, December 5, 1974.

20.  Partek  Corporation  of  Houston,  "Partek   Liqua-Blaster   TM,"
     Houston, Texas, 1976.

21.  Penningtpn, J.C., untitled letter to T.B.  Ray  at  Newport  News
     Shipbuilding  and Dry Dock Company, U.S. Environmental Protection
     Agency, National Field Investigations Center,  Denver,  Colorado,
     August 1974.

22.  Price,  R.A.,  "Texstar,  Inc.  Automatic   Descaling   Equipment
     Demonstration  at Avondale Shipyards, Inc.," memorandum, Avondale
     Shipyards, Inc., New Orleans, Louisiana, June 24, 1975.
                                 116

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23.   Bay, T.B.,  "Comments  on  the  Draft  Development  Document  for
     Machinery  and  Mechanical Products Manufacturers," letter to the
     U..S. Environmental Protection Agency, Newport  News  Shipbuilding
     and Dry Dock Co., Newport News, Virginia, August 1975.

24.   Ray, T.B., "Water Pollution Control Plan," submitted to the State
     of Virginia Water Control Board as a requirement of NPDES  Permit
     fVA  0004804, Newport News Shipbuilding and Dry Dock Co., Newport
     News, Virginia 1975.

25.   Ticker, A. and Rodgers, S.,  Abatement  of  Pollution  Caused  by
     Abrasive  Blasting; Status in Naval Shipyards, Report 4549, Naval
     Ship Research and Development Center,  Bethesda, .Maryland,  July
     1975.

26.   Shierman,  E.G., A Demonstration of the Myers-Sherman Vactor Model
     700,  U.S.  Navy,  Long  Beach  Naval   Shipyard,   Long   Beach,
     California, 1975.

27.   U.S. Congress, Current  Status  of  Shipyards,  1974  -  Part  2t
     hearings  before  the  Seapower  Subcommittee of the Committee on
     Armed Services, House of

28.   U.S. Department of  Commerce  and  U.S.  Department  of  Defense,
     Principal  Shipbuilding  and  Repair  Facilities  of  the  United
     States, Naval Sea Systems Command, Washington, DC, 1970.

29.   U.S.  Department  of  Defense,  "Military  Specification:  Paint,
     Antifouling,    Vinyl-Red     (Formula   No.   121/63),   Military
     Specficiation MIL-P-15931B, Amendment 2,  Washington,  DC,  April
     13, 1970.

30.   U.S.  Department  of  Defense,  "Military  Specification:  Primer
     Coating,   Shipyard,   Vinyl-Red  Lead   (Formula  119),  Military
     Specification MIL-P-15929C, Washington, DC, October 24, 1972.

31.   U.S.  Department  of  the  Navy,  Design  Manual   -   Drydocfring
     Facilities,   DM-29,   Naval   Facilities   Engineering  Command,
     Alexandria, Virginia, February 1974.

32*   U.S. Department of the Navy,  Docking  Instructions  and  Routine
     Work  in  Drydock,  Naval  Ships1  Technical Manual Chapter 9070,
     Naval Sea Systems Command, Washington, DC, November 1, 1972.

33.   U.S. Department of the  Navy,  Environmenta1  Protection  Manual,
     OPNAV   Instruction   6240.3,   Office  of  the  Chief  of  Naval
     Operations, Washington, DC, 1975.
                                 117

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34.  U.S.  Department  of  the  Navy,   Final   Environmental   Impact
     Statement;   Abrasive  Blasting  of Naval Shipsj Hulls, Naval Sea
     Systems Command, Washington, DC, November 1975.

35.  U-S. Department  of  the  Navy,  "Military  Specification:  Sand,
     Sandblast;  and  Grain,  Abrasive  -  Ship  Hull Blast Cleaning,"
     Military  Specification  MIL-S-22262  (Ships),  Washington,   DC,
     December 4, 1959.

36.  U.S. Department of the Navy,  "»Mini  Scope1:   Shipalt  ARD-193,
     Industrial  Waste  Disposal,: Boston Naval Shipyard, Code 2060.2,
     Boston, Massachusetts, September 12, 1975..
                            o
37.  U.S. Department  of  the  Navy,  P-174  Drydock  Water  Pollution
     Abatement,  Fiscal  Year  -  1979, Military Construction Program,
     Long Beach Naval Shipyard, Long Beach, California, May 1, 1976.

38.  U.S. Department of the Navy, "Revised  Sandblasting  Procedures,"
     Naval  Ships'  Technical  Manual Chapter 9190, Amendment 1, Naval
     Sea Systems Command, Washington, DC, August 1, 1975.

39.  U.S. Department of the  Navy,  A  Study  of   Sediments  and  soil
     Samples  From  Pearl Harbor Area, Facilities  Engineering Command,
     Civil Engineering Laboratory,  Port  Hueneme,  California,  March
     1973.

40.  U.S. Environmental Protection Agency, "Determination of Metals in
     Salt Water by Atomic Absorption," National  Field  Investigations
     Center, Denver, Colorado, 1974.

41.  U.S. Environmental Protection Agency, Draft   Report  to  the  San
     Diego  Regional Water Quality Control Board on Guidelines for the
     Control of Shipyard  Pollutants,  National  Field  Investigations
     Center, Denver, Colorado, July 1, 1974.

42.  U.S.  Environmental  Protection  Agency,  Rationale   for   Water
     Pollution  Control  at  Shipbuilding  and Ship Repair Facilities,
     National Field Investigations Center,  Denver,  Colorado,  August
     1974.

43.  U.S. Environmental Protection Agency, "Study  Plan  for  Shipyard
     Field   Survey,   Newport   News,   Virginia,"   National   Field
     Investigations Center, Denver, Colorado, May  1974.

44.  Virginia Institute of Marine Science, Study of Channel Sedimentsf
     James River and Hampton Roads Area, Gloucester  Point,  Virginia,
     August 1971.
                                 118

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45.   Carr, Dodd S.  and  Kronstein,  Max,  "Anti-fouling  Mechanism  of
     Shipbottom   Finishes,"  Modern  Paint  and  Coatings,  Palmerton
     Publishing Co., New York, New York December 1975, pp. 23-27.

46.   "At  Last,  A.  Lasting  Bottom  Paint,"  Washington  Star   News,
     Washington, DC, April 4, 1976.

47.   "Bay's  Project  on  Schedule,"   World   Dredging   and   .Marine
     Construction,  Symcon Publishing Co., San Pedro, California, April
     1976, p. 8.

48.   Hassani, Jay J.  and  Millard,  Charles  F. ,  "Graving  Dock  for
     300,000-Ton  Ships," Civil Engineering, American Society of Civil
     Engineers, New York, New York; June 1971.

49.   "Navy Device Soaks Up Spilled Oil," Navy Times,  Washington,  DC,
     April 12, 1976, p. 44.

50.   "New Paint Keeps Barnacles At Bay," Navy Times,  Washington,  DC,
     April 19, 1976, p. 3.

51.   Clark, Allen,  "Shipyard Problems with Oily  Wastes,"  Proceedings
     of  the International Conference on Waste Oil Recovery and Reuse,
     February 12-14,  1974,  Information  Transfer,  Inc.,  Rockville,
     Maryland, 1974.

52.   United States Department of Defense and Department  of  Commerce,
     Principal  Shipbuilding  and  Repair  Facilities  of  the  United
     States, Office of the Coordinator for Ship Repair and Conversion,
     Naval Sea Systems Command, September 1, 1978.
                                 119

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                              SECTION XI

                               GLOSSARY


Anticorrosive paints - the initial layer(s)  of paint on a ship»s hull.
     The purpose of these paints is to prevent rusting.

Antifouling paints - the final layer(s) of paint applied to  a  shipfs
     hull.   They  inhibit  the growth of marine organisms on a ship's
     hull.

Bare Metal - hull metal that has had all paint  and  marine  organisms
     abraded in preparation for repainting..

Building Basins - a graving dock used solely for ship construction.

Eilge water - water and oil that collects in the lower hull.

Bilge  blocks  -  side  blocks  placed on the drydock floor.  They are
     located according to the dimensions specific to a particular ship
     and help stabilize and support the drydocked ship.

Bilge block slides - raised  lateral  tracks  built  into  many  older
     docks, used to move and position bilge blocks-

Broomed clean - see "Scraped or Broomed clean".

Closed  cycle  blaster  -  a  type  of  abrasive  blaster  that reuses
     abrasive, usually steel shot, and often  collects  removed  paint
     and marine organisms.

Cooling  water - non-potable water used for shipboard purposes such as
     air-conditioning  and  condenser  cooling  during  the  drydocked
     period.

Deflooding - the pumping out of the flooded (filled) drydocks.

Dewatering - see deflooding.

Dock leakage - hydrostatic relief water, gate seepage, and other water
     leakage  other  than  ship  originating wastes that leak into the
     dock floor.

Drainage discharge - the daily effluent from a drydock..  This does not
     include deflooding water.

Dregs - silt, grit, or other  particles  deposited  on  a  dock  floor
     during dewatering.
                                  121

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Dry  abrasive  blasting  - a process to remove paint, rust, and marine
     organisms from a ship1s hull.  The abrasive usually a copper slag
     or sand, is conveyed in a medium of .high pressure air  through  a
     nozzle.

Drydock  - either a graving dock or a floating drydock.  Also.to place
     a ship in drydock.

Flap gate - a rigid one piece gate hanged at the bottom.

Floating - raising of a submerged floating drydock.

Floating caisson gate - the most common type of graving dock gate.  It
     is floatable and can be moved to permit, entry  and  departure  of
     the ship.

Floating  drydock  - a submersible moveable platform to enable repairs
     and maintenance of ships out of water.

Flooded dock - the filled dock following flooding.

Flooding - the filling of a graving dock with water, to permit entry or
     departure of a ship.

Flush deck construction - a flat dock floor not having permanent bilge
     block slides.

Fresh grit - unused abrasive.

Front loaders - a type of machinery, similar to a bull dozer  used  to
     scrap collect and transfer spent paint, grit and marine organisms
     that collect on the dock floor during blasting.

Gate  - the closure that separates a graving dock from the harbor.  It
     is removed to permit entry and departure of the ship.

Graving dock - a dry basin, below water level that is used for  repair
     and maintenance of ships.

Grit - abrasive.

Hydroblasting  -  the  use  of  a high pressure water stream to remove
     paint, rust, and marine organisms from a ship's hull.

Hydrostatic relief - the water that leaks into a  dock  through  holes
     and  cracks  in  the  floors  and  walls of a graving dock.  This
     equilibrates groundwater pressure.
                                 122

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Keel blocks - blocks positioned on the floor of the  dock,  fitted  to
     match  the  keel  surface  of  the  ship.   The drydocked ship is
     positioned on the blocks.

Launch water - the water in a flooded graving dock.

Manual clean up - use of shovels, brooms, and other equipment which is
     not power operated to clean the dock floor.

Mechanical clean up - use of machinery, such  as  front  end  loaders,
     mechanical sweepers, or vacuum cleaners to clean the dock floor.

Miter  gate  -  a  pair of gate leaves* hinged at the dock walls which
     swing open to allow passage of a ship into  and  from  a  graving
     dock.

Primer - see "anticorrosive paints."

Sand - often used to describe any dry abrasive.

Sand blast - dry abrasive blasting.

Sand  sweep - a light dry abrasive blast used to remove only the outer
     layers of paint and marine growth from a ships hull.

"Scraped or  Broomed  Clean"  -  using  shovels,  mechanical  loaders,
     mechanical  sweepers,  or  brooms  to  remove  abrasive  blasting
     debris.

Scupper boxes - containers used to collect water that runs off a  ship
     deck.

Shipboard   wastes  -  all  effluent  discharges  originating  from  a
     drydocked ship.   Included  are  sanitary  wastes,  bilge  water,
     cooling water, and cleaning wastes.

Sinking  -  flooding  of  caissons and lowering of floating drydock to
     permit a ship to be positioned over the dock prior to floating of
     the dock and docking.

Slurry blasting - see "wet abrasive blasting,"

Soil chutes - flexible hoses, usually made of rubber coated  nylon  or
     canvas  used  to transfer shipboard wastes from the docked vessel
     to the appropriate disposal system.

Spent abrasive - used grit and spent paint, rust, and marine organisms
     that collect on the dock floor during blasting.
                                 123

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Stripping - see "drainage discharge."

Wash down - the hosing down  of  the  dock,  and  sides  of  the  ship
     following docking to remove silt, marine organisms, etc.

Water  cone abrasive blasting - a type of blasting that uses a cone of
     water to surround the stream of air and abrasive  as  they  leave
     the nozzle.

Wet  abrasive  blasting  - a process to remove paint, rust, and marine
     growth from ship's hulls, in which high pressure water propels an
     abrasive.

White metal - see "bare metal,"
                                 124

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                                     TABLE

                                   METRIC  TABLE

                                 CONVERSION TABLE

MULTIPLY  (ENGLISH UNITS)                   by                TO OBTAIN  (METRIC UNITS)

     ENGLISH UNIT      ABBREVIATION    CONVERSION   ABBREVIATION   METRIC UNIT
acre                    ac
acre - feet             ac ft
British Thermal
  Unit                  BTU
British Thermal
  Unit/pound            BTU/lb
cubic feet/minute       cfm
cubic feet/second       cfs
cubic feet              cu ft
cubic feet              cu ft
cubic Inches            cu In
degree Fahrenheit       °F
feet                    ft
gallon                  gal
gallon/minute           gpm
horsepower              hp
Inches                  in
Inches of mercury       in Hg
pounds                  Ib
million gallons/day     mgd
mile                    mi
pound/square
  inch (gauge)          psig
square feet             sq ft
square Inches           sq in
ton (short)             ton
yard                    yd
       0.405
    1233.5

       0.252
ha
cu m

kg cal
0.555
0.028
1.7
0.028
28.32
16.39
0.555(6F-32)*
0.3048
3.785
0.0631
0.7457
2.54
0.03342
0.454
785
1.609
kg cal /kg
cu m/min
cu m/min
cu m
1
cu cm
•C
m
1
I/sec
kw
cm
atm
kg
cu m/day
km
(0.06805 psig +1)*  atm
       0.0929       sq m
       6.452        sq cm
       0.907        kkg
       0.9144       m
* Actual conversion, not a multiplier
hectares
cubic meters

kilogram - calories

kilogram calories/kilogram
cubic meters/minute
cubic meters/minute
cubic meters
liters
cubic centimeters
degree Centigrade
meters
liters
liters/second
killowatts
centimeters
atmospheres
kilograms
cubic meters/day
kilometer

atmospheres (absolute)
square meters
square centimeters
metric ton (1000 kilograms)
meter
                                         126
                                                 U. S. GOVERNMENT PRINTING OFFICE : 1979 C - 307-065

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United States
Environmental Protection
Agency
Washington DC 20460
————————^———  —                                                                    •                       Special
OHicial Business                                                                                                              Fourth-Class
Penalty (or Private Use $300                                                                                                    pate
                                                                           •' rv,.r.                                          Book

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