The following item is excerpted from an upcoming issue of a Pacific NW
boating magazine. It outlines an interesting situation that doubtlessly
exists throughout the country, as the EPA is the agency ultimately in
charge of regulating boatyard operations.

Long, so pour a cup of coffee or proceed to the next thread. :-)

Conversation with "Deep Draft"

"We should probably be meeting in secret," joked my source. "For
reasons that will be pretty obvious, I'd prefer that what I'm going
to tell you not be traced too easily back to me. Maybe we should use a
code name. Since 'Deep Throat' has already been used up, let's go
with 'Deep Draft'."

It will be important to know that Deep Draft is a highly placed
individual in a major shipyard operation here in the Pacific NW. Deep
Draft has been involved environmental testing, reporting, and assuring
his or her operation's compliance with regulatory statues for more
than a decade. It's also important to know that a situation now
flying well under the public radar has the potential to eliminate many
of the essential services we boaters depend upon.

Deep Draft: Are you familiar with the NPDES?

Nor'westing: Not really, no.

Deep Draft: The EPA, the national environmental protection agency,
empowered the Washington State Department of Ecology to issue permits
to sources of pollution. The goal was to reduce the amount of the
pollution by requiring various industries to adhere to regulations as a
condition of the permit. The first NPDES permit for boatyards was
issued in 1992. What that permit required us to do was to sample and
test our storm water runoff that flowed out of our shipyard and into
the sound, the ship canal, or whatever the receiving body of water
happens to be.

Deep Draft (continues): In 1997, they reissued another permit. It was
more of the same thing, we sampled the storm water run off and sent in
the results. We didn't get a heck of a lot of guidance, and there
wasn't a lot of on-site field work from the Department of Ecology.
Essentially they were just trying to establish some sort of baseline
for future analysis.

Nor'westing: Now when you mention this permit, is it a specific
permit for an individual boatyard or is it a general license for an
entire industry?

Deep Draft: It's what's called a 'general permit,' and all
yards have different standards under the general permit based on what
the receiving waters are. A yard on a river will have to conform to
different standards of the permit than a yard on a lake or on Puget
Sound. The original permit in '92 and the renewed permit in '97 had
target numbers that would have been nice to hit. What we're measuring
for in the storm water runoff is copper, total suspended solids, and
oil or grease. Now of course the real culprit that everybody is focused
on is copper, as we certainly don't get a lot of oil or grease in
this industry compared to the amount of oil that simply washes in off
the streets. Our contribution to the oil and grease contamination is
going to be insignificant, and the same with total suspended solids. We
obviously have a lot of copper in our bottom paints.

Deep Draft (continues): When they wrote the second NPDES permit in
'97, they concluded that they would need to rewrite the permit at a
later date. When the second NPDES permit expired in 2002, they extended
the permit so that boatyards could continue to operate. We then began a
series of meetings that included the boatyard owners and the NMTA
(Northwest Marine Trade Association) as one group, the Department of
Ecology as a second party, and environmental activists (mainly
represented by Sue Joerger and her group, the Puget Soundkeepers
Alliance), as a third party. We met for several years, during which
time the DOE was never able to produce a draft version of a new NPDES
permit. When they finally did come up with a draft, we all sat and
argued through the pros and cons of it, and then the DOE issued the
final version of the permit in November of last year.

Deep Draft (continues): The new permit has in it some benchmarks. The
Department of Ecology permit writers came up with some numbers that we
thought would be difficult, but not impossible to meet- especially if
we looked harder for point sources of pollution and invested in some
new technology. Under the new permit, if a yard exceeds certain levels
in the laboratory testing it is forced to jump through various hoops
depending on the severity of the excess. The requirements can vary
between having to write a report outlining the steps you are taking to
reduce the problem, paying a monetary fine, etc. It gets increasingly
severe until after six failures to meet the testing requirements the
state can force your business to shut down entirely.

Deep Draft (continues): Right after the permit went into effect in
November, Sue Joerger's group filed an appeal. They didn't feel the
new restrictions were stringent enough. As a response to Sue
Joerger's appeal, the NMTA also filed an appeal. The NPDES permit
that we all need to operate is now before the Pollution Control
Hearings Board.

NOTE: The copper runoff for which boatyards are required to measure is
not typically the result of pressure washing vessels during haulout.
All boatyards are required to collect water that runs off during
pressure washing and subject it to treatment and filtration prior to
discharge into any adjoining water. The copper and other materials
collected by filtration are hauled off to a hazardous waste site. The
copper runoff that concerns the environmental activists and the DOE are
those miscellaneous amounts that can occur in an area merely because
there is a high presence of copper present in the surrounding
environment. Raindrops falling against the dried bottom paint of a
vessel sitting on the hard before falling onto the pavement might be a
typical source.

Nor'westing: In the broad scope of this process, which you say began
in 1992, have boatyards in general been progressing toward lower
standards of pollution? Has the current system worked to the degree
that boatyards are working harder to contain copper and other wastes in
order to meet the permit requirements? Have the readings improved?

Deep Draft: Yes and no. That's a roundabout answer meaning that I
have to explain. Initially we were given no direction about how or
where to sample. Depending on what a boatyard did, their numbers would
be very good, or very bad, or accurate. Some were so far off the scale
on the high side that they must have been taking the readings inside
the pressure washing tank, and some were so low they were totally
unbelievable as well. Once in a while we would get a site visit from
somebody at the DOE, and they would confirm that we were sampling at an
acceptable location or they would ask us to change it. The bottom line
is that if you throw out the numbers that are off the scale on the high
side and throw out the numbers that are too good to be true, almost
nobody is currently passing.

Nor'westing: If there's a lack of progress, could it be due to the
fact that testing has now been standardized and that has changed the
results?

Deep Draft: There still isn't a lot of guidance. We had an on-site
inspection and they asked me to collect some runoff for a test. When I
began collecting the runoff, one of the inspectors told me I couldn't
use that spot, even though that's the same spot I took samples for
the previous 15 years. A second inspector on site that day disagreed
with his counterpart and they had an argument about whether my original
test site or the new site they were requiring me to use was actually
the better choice.

Deep Draft (continues): The new benchmarks in the NPDES permit are
going to be very difficult to meet, but the industry is committed to
trying to meet them. Before, there never was really any penalty for
failure to meet the benchmarks, but now there are penalties up to and
including being put out of business. It's a serious concern. The
problem with the appeal filed by the Puget Soundkeepers Alliance and
their affiliated groups is that they want water quality standards that
are so severe that they virtually guarantee that nobody could possibly
pass. Under the environmentalists' standards, every single boatyard
in the entire Puget Sound area is in danger of being shut down. I have
spoken to some yards that have cleaned, swept, and pressure washed
their entire yards in an attempt to eliminate any residual traces of
copper- and they now have higher levels of discharge than the did
before. It can be frustrating. We're now investigating building huge
catch basins to intercept all the rainwater that flows through the yard
and filter it in huge socks.

Nor'westing: Is there any chance the standards are unrealistically
high?

Deep Draft: I can say that some of people enforcing the standards have
unreasonable expectations. We recently had an inspector from the
Department of Ecology on site, and she noticed a water hose, hooked up
to the city's public water supply, that had some water running from
the end of it. Some boaters were going to use it to provide cooling
water to a saildrive that they were tuning up. She told me that I had
to stop that "activity" immediately. When I asked her why, she said
it was because the city drinking water has been chlorinated and
therefore it wasn't permissible to allow it to flow into {name of
industrial waterway omitted to preserve Deep Draft's anonymity}.

Nor'westing: She actually told you that you couldn't allow the City
of Seattle's drinking water to flow into the waterway outside your
yard because the city water supply was a pollutant?

Deep Draft: Yes, she did. The same water that the city says I can drink
from the tap, that I wash my hair with, and bathe my babies in is
supposed to be hazardous that it can't flow into {waterway}. Let me
tell you, I'd drink tap water, but I would never consider drinking
out of {waterway}.

**************

At Deep Draft's suggestion, we called Michael Campbell of the NMTA to
ask about names of public officials who could be approached by boaters
concerned about the potential impact of the environmentalists' appeal
of the NPDES permit. Campbell suggested that it probably isn't yet
the appropriate time for a lot of public input. "After Sue Joerger
and her group appealed on behalf of the environmentalists, the NMTA
also appealed on behalf of the boatyards. There were ten things we
didn't like in the permit, but one reason we appealed was so that we
would be at the table during any further discussions of this issue.
There's a hearing July 10-12 at the state Pollution Control Hearings
Board, and we don't know what will happen. The hearings board really
has two options- one is to send the permit back to the Department of
Ecology and ask that it be reworked and the other is to hear all sides
and then decide to let the permit stand as written.

We will keep our readers posted as this issue progresses. Meanwhile, if
your local boatyard appears to be paying even more attention than
normal to environmental issues be assured that it is seriously
concerned with complying with the NPDES permit.
Despoiling the public ecosystem should never be an acceptable path to
private profit, but boatyards making a sincere effort to be good
stewards of the environment should not be subjected to fantasyland
standards that make operation impractical, if not impossible.

Deep Draft conjectured: "I think the environmental activists could be
using the boatyards as a stalking horse. Next year, the NPDES permits
come up for some of the largest and heaviest industries in the area.
They probably think that it's easier to beat up on a small group like
the boatyards, and then use those standards as a precedent when
demanding changes from some of the much larger sources of serious
pollution." There's a good chance that he or she might be right.

Deep Draft: I can say that some of people enforcing the standards have
unreasonable expectations. We recently had an inspector from the
Department of Ecology on site, and she noticed a water hose, hooked up
to the city's public water supply, that had some water running from
the end of it. Some boaters were going to use it to provide cooling
water to a saildrive that they were tuning up. She told me that I had
to stop that "activity" immediately. When I asked her why, she said
it was because the city drinking water has been chlorinated and
therefore it wasn't permissible to allow it to flow into {name of
industrial waterway omitted to preserve Deep Draft's anonymity}.

Well, there you have it, a fine example of environmental nonsense taken to
illogical extremes.

writes:

Nor'westing: She actually told you that you couldn't allow the City
of Seattle's drinking water to flow into the waterway outside your
yard because the city water supply was a pollutant?

Deep Draft: Yes, she did.

Precious.

wrote in message
oups.com...
The following item is excerpted from an upcoming issue of a Pacific NW
boating magazine. It outlines an interesting situation that doubtlessly
exists throughout the country, as the EPA is the agency ultimately in
charge of regulating boatyard operations.

Long, so pour a cup of coffee or proceed to the next thread. :-)


EPA, spotted owls, tree huggers, environmental extremists.................

And one wonders why we can't explore and drill for oil in the US.

Thanks for the article Chuck.

Del Cecchi wrote:
"Bill Kearney" wrote in message
t...
Deep Draft: I can say that some of people enforcing the standards
have
unreasonable expectations. We recently had an inspector from the
Department of Ecology on site, and she noticed a water hose, hooked up
to the city's public water supply, that had some water running from
the end of it. Some boaters were going to use it to provide cooling
water to a saildrive that they were tuning up. She told me that I had
to stop that "activity" immediately. When I asked her why, she said
it was because the city drinking water has been chlorinated and
therefore it wasn't permissible to allow it to flow into {name of
industrial waterway omitted to preserve Deep Draft's anonymity}.

Well, there you have it, a fine example of environmental nonsense taken
to
illogical extremes.

They know how to use the government to achieve their aim of shutting down
the boatyards and thus getting rid of those carbon emitting, kayak
annoying, boats.

del

The amazing thing is that the lead dog in the environmentalist movement
lives aboard her boat at a local marina. One of her neighbors has
offered to take a photo of her washing her boat (with soap, of course).
Now that would make an interesting addition to the Deep Draft series.
:-)

I'm very much in favor of working and playing in a manner that has the
least potential to harm the environment, but not at all in favor of
some theory that people should all commit suicide and let the entire
planet go back to nature. A reasonable balance is desirable. The kooks
that want to make an issue out of city drinking water running into an
industrial waterway do more harm than good. The rape and pillage
profiteers love to use the wacky extremists to typify anybody with a
concern for conservation, preservation, or even general esthetics.

JimH wrote:
wrote in message
oups.com...
The following item is excerpted from an upcoming issue of a Pacific NW
boating magazine. It outlines an interesting situation that doubtlessly
exists throughout the country, as the EPA is the agency ultimately in
charge of regulating boatyard operations.

Long, so pour a cup of coffee or proceed to the next thread. :-)


EPA, spotted owls, tree huggers, environmental extremists.................

And one wonders why we can't explore and drill for oil in the US.

Thanks for the article Chuck.



There's no truth to the propgandists's claims that oil companies can no
longer explore for oil or open new wells in the US. Like the
environmental extremists, people who tell you that have placed their
personal agenda above the truth.

The following like will take you to a Shell Oil website, where you can
read about a major expansion of Shell Oil activity in Alaska during
2005.

http://tny.se/1ig

wrote in message
oups.com...

JimH wrote:
wrote in message
oups.com...
The following item is excerpted from an upcoming issue of a Pacific
NW
boating magazine. It outlines an interesting situation that
doubtlessly
exists throughout the country, as the EPA is the agency ultimately
in
charge of regulating boatyard operations.

Long, so pour a cup of coffee or proceed to the next thread. :-)


EPA, spotted owls, tree huggers, environmental
extremists.................

And one wonders why we can't explore and drill for oil in the US.

Thanks for the article Chuck.



There's no truth to the propgandists's claims that oil companies can no
longer explore for oil or open new wells in the US. Like the
environmental extremists, people who tell you that have placed their
personal agenda above the truth.

The following like will take you to a Shell Oil website, where you can
read about a major expansion of Shell Oil activity in Alaska during
2005.

http://tny.se/1ig

How about the outer continental shelf and gulf of Mexico? I believe the
argument relates to how much area is off limits. And how many new
refineries have been built in the last 20 years?

del

Del Cecchi wrote:
wrote in message
oups.com...

JimH wrote:
wrote in message
oups.com...
The following item is excerpted from an upcoming issue of a Pacific
NW
boating magazine. It outlines an interesting situation that
doubtlessly
exists throughout the country, as the EPA is the agency ultimately
in
charge of regulating boatyard operations.

Long, so pour a cup of coffee or proceed to the next thread. :-)


EPA, spotted owls, tree huggers, environmental
extremists.................

And one wonders why we can't explore and drill for oil in the US.

Thanks for the article Chuck.



There's no truth to the propgandists's claims that oil companies can no
longer explore for oil or open new wells in the US. Like the
environmental extremists, people who tell you that have placed their
personal agenda above the truth.

The following like will take you to a Shell Oil website, where you can
read about a major expansion of Shell Oil activity in Alaska during
2005.

http://tny.se/1ig

How about the outer continental shelf and gulf of Mexico? I believe the
argument relates to how much area is off limits. And how many new
refineries have been built in the last 20 years?

del


The fact is that no oil company has even proposed the construction of a
new refinery in a very long time. It is in the oil companies' best
interest to limit the number of refineries, and many of the major oil
companies are more concerned with shutting down their existing
refineries than in establishing new ones. There was a well publicized
case where one of the major oil companies announced it was shutting
down a refinery. An independent oil company stepped forward and offered
to pay fair market value for the refinery, (mega millions) but the big
oil company declined and said that it would rather bulldoze the site.
That should tell us all that there are more mega-millions to be made by
tearing down a refinery than by operating it or selling off the
equipment to somebody else who would.

You often hear the radio rabble rousers blame "the liberals" for
preventing the establishment of new oil refineries in the US, but the
oil companies have no collective interest in increasing refinery
capacity. Just try to find a current example of an application to build
an oil refinery of any type, let alone one that is being blocked by
"liberals". :-)

wrote in message
ups.com...

Del Cecchi wrote:

How about the outer continental shelf and gulf of Mexico? I believe the
argument relates to how much area is off limits. And how many new
refineries have been built in the last 20 years?

del


The fact is that no oil company has even proposed the construction of a
new refinery in a very long time. It is in the oil companies' best
interest to limit the number of refineries, and many of the major oil
companies are more concerned with shutting down their existing
refineries than in establishing new ones. There was a well publicized
case where one of the major oil companies announced it was shutting
down a refinery. An independent oil company stepped forward and offered
to pay fair market value for the refinery, (mega millions) but the big
oil company declined and said that it would rather bulldoze the site.
That should tell us all that there are more mega-millions to be made by
tearing down a refinery than by operating it or selling off the
equipment to somebody else who would.

You often hear the radio rabble rousers blame "the liberals" for
preventing the establishment of new oil refineries in the US, but the
oil companies have no collective interest in increasing refinery
capacity. Just try to find a current example of an application to build
an oil refinery of any type, let alone one that is being blocked by
"liberals". :-)


I watched an interview the other day with a big-wig from one of the major
oil companies (forget which one, but it doesn't matter). He claimed that
the environmental objections and permit obstacles were the major reasons for
the lack of new refineries in the US. He claimed that mucho dollars were
being spent to upgrade and make more efficient existing refineries as the
permitting process is not as complex.

So ... who to believe?

Also have to think about electrical energy. Power companies didn't stop
building nuclear power plants because they wanted to limit the supply of
electricity. They stopped because it became cost prohibitive to go through
the permitting and construction process.

RCE

RCE wrote:
wrote in message
ups.com...

Del Cecchi wrote:

How about the outer continental shelf and gulf of Mexico? I believe the
argument relates to how much area is off limits. And how many new
refineries have been built in the last 20 years?

del


The fact is that no oil company has even proposed the construction of a
new refinery in a very long time. It is in the oil companies' best
interest to limit the number of refineries, and many of the major oil
companies are more concerned with shutting down their existing
refineries than in establishing new ones. There was a well publicized
case where one of the major oil companies announced it was shutting
down a refinery. An independent oil company stepped forward and offered
to pay fair market value for the refinery, (mega millions) but the big
oil company declined and said that it would rather bulldoze the site.
That should tell us all that there are more mega-millions to be made by
tearing down a refinery than by operating it or selling off the
equipment to somebody else who would.

You often hear the radio rabble rousers blame "the liberals" for
preventing the establishment of new oil refineries in the US, but the
oil companies have no collective interest in increasing refinery
capacity. Just try to find a current example of an application to build
an oil refinery of any type, let alone one that is being blocked by
"liberals". :-)


I watched an interview the other day with a big-wig from one of the major
oil companies (forget which one, but it doesn't matter). He claimed that
the environmental objections and permit obstacles were the major reasons for
the lack of new refineries in the US. He claimed that mucho dollars were
being spent to upgrade and make more efficient existing refineries as the
permitting process is not as complex.

So ... who to believe?

Also have to think about electrical energy. Power companies didn't stop
building nuclear power plants because they wanted to limit the supply of
electricity. They stopped because it became cost prohibitive to go through
the permitting and construction process.

RCE


The deliberate reduction of refinery capacity by the oil companies has
been a matter of policy for over a decade.

For instance:

"As observed over the last few years and as projected well into the
future, the most critical
factor facing the refining industry on the West Coast is the surplus
refining capacity, and the
surplus gasoline production capacity. The same situation exists for the
entire U.S. refining
industry. Supply significantly exceeds demand year-round. This results
in very poor refinery
margins, and very poor refinery financial results. Significant events
need to occur to assist
in reducing supplies and/or increasing the demand for gasoline."
Internal Texaco document, March 7, 1996

"A senior energy analyst at the recent API (American Petroleum
Institute) convention
warned that if the U.S. petroleum industry doesn't reduce its
refining capacity, it will never
see any substantial increase in refining margins...However, refining
utilization has been
rising, sustaining high levels of operations, thereby keeping prices
low."
Internal Chevron document, November 30, 1995


Complete attribution of those "internal documents" and more of the
story from a US Senate investigative report, (now a few years old but
obviously still relevant):


tp://wyden.senate.gov/leg_issues/reports/wyden_oil_report.pdf


You can read just exactly how the major oil companies deliberate
closing of US refineries took nearly 900,000 bbl per day of refined
product off the US market in an admitted effort to increase the gross
margins on refined product.

All of which impacts the costs involved with operating a boat, lest
anybody think we're drifting too far off topic. :-)