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Throughout the last five years, Todd Pacific Shipyards' management has set the example of environmental stewardship by
proactively and comprehensively changing the way the business is run. As a key member of the Seattle waterfront
community and a highly productive waterfront industry, Todd understands that it is essential to protect the
water quality of Elliott Bay and prevent pollution to ensure ecological value and prosperity for future generations.
To reach these goals, Todd has implemented physical upgrades and instituted workplace requirements that
extend well beyond the minimum regulatory requirements for environmental protection. Many of these
environmental improvements have also created additional commercial benefits: streamlining the handling
of materials in shipyard production, and providing concurrent safety and business improvements.
Read more about what Todd is doing in the areas below:
ENVIRONMENTAL IMPROVEMENTS
Contaminated Industrial Stormwater and Dockwater Management. In 2003, Todd completed
construction of an
industrial stormwater collection and treatment system that prevents all discharge of contaminated industrial
stormwater to Elliott Bay. Throughout the company's 88-year history, rainfall that collected on facility pavements
naturally drained to catch basins and discharged to surface waters via numerous nearshore outfalls. Todd
evaluated the potential risks of stormwater pollution, and determined that the most effective and reliable
system to protect surface water and reduce risk of contamination of sediments was to develop a system for collection
of stormwater from the primary industrial yard pavements. This runoff is now detained and discharged to the
sanitary sewer for treatment at King County's treatment plant.
The contaminated industrial stormwater collection system is designed to handle a 10-year storm event, providing
450,000 gallons of detention, with first stage treatment to remove solids, oils, and greases. The new system
has eliminated all routine industrial stormwater discharges to the Elliott Bay receiving waters. With a total
collection area of approximately 10 acres, the system is two times larger than required to meet regulatory
National Pollutant Discharge Elimination System (NPDES) requirements. The collection and treatment system required a significant infrastructure investment
of approximately $3 million.
Additionally, Todd implemented upgrades to its dockwater collection and pretreatment system and adopted
a comprehensive abrasive grit blast management plan, wihch prevents abrasive grit from contacting storm
and surface waters. Todd worked with employees at all stages of grit handling to develop and implement a
comprehensive grit management program which containerizes spent grit at its source, minimizing rehandling of
grit and reducing the potential for grit to be tracked through the yard or allowed to enter storm drains or
surface waters. In the spring of 2004, Todd was selected by the City of Seattle, the Greater Seattle Chamber
of Commerce, and Resource Venture group as the recipient of the BEST (Businesses for an Environmentally Sustainable
Tomorrow) Award in the Stormwater Pollution Prevention category.
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Waste Minimization. Todd has significantly reduced the environmental impacts of the facility through waste
minimization. Two key programs reduce use of grit blast and solvents. These are voluntary efforts - not
required by regulation.
Todd has prioritized the use of hydroblasting to remove paint from ship hulls, effectively reducing
the amount of grit used at the facility, in order to reduce the risk of sediment recontamination and
protect the waters of Elliott Bay. The amount of grit abrasive purchased has been reduced by approximately
30 percent. In 2001, Todd purchased 3.5 million pounds of grit; in 2003, a total of 2.5 million pounds were
purchased. 60 to 70 percent of paint removal practice at Todd now involves hydroblasting instead of abrasive
grit blasting. This percentage is expected to increase due to Todd's continued dedication to reducing the amount
of abrasive grit blasting.
Additionally, Todd has switched to paint containing reduced quantities of volatile organic compounds in all
operations and minimized solvent usage. An all-encompassing company policy is to reduce the amount
of hazardous materials used and to switch to more environmentally friendly alternatives whenever possible.
Todd is using two lower-VOC solvents, produced by Tacoma’s Inland Technologies, for various applications.
The first alternative solvent is Breakthrough which is now used exclusively to clean machinist's
equipment. Breakthrough contains less total aromatic content than previous solvents, generates less non-volatile
residue, and can be recycled. Through use of this alternative cleaner, Todd has reduced hazardous waste
disposal of machine cleaning solvent from 760 gallons to zero gallons over the past six years. The usage
of this solvent also has beneficial economic results, with an estimated minimum savings of over $15,000 a year.
The second alternative solvent product is EP921 which has replaced methyl ethyl ketone (MEK) for
paint equipment cleanout at one of the Todd paint stations, with plans for expanding to additional stations.
EP921 contains less volatile organic compounds (VOC) content than MEK, is not a regulated hazardous air
pollutant (HAP), and essentially does not evaporate. It is recycled numerous times in an onsite reclamation
unit. Current use of EP921 at one paint station is avoiding hazardous waste disposal of 680 gallons of
MEK per year and it uses significantly less gallons to do the same cleaning job. After payback of the on-site
reclamation unit, estimated annual cost savings at one paint station is over $2,300 per year.
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Contaminated Sediment Cleanup. In the summer of 2004, Todd began a comprehensive
remedial action to remove contaminated marine sediments which have accumulated offshore of the Todd
facility throughout the history of shipyard operations. Remedial action will take two years,
coordinated with shipyard business activities, and will exceed U.S. Environmental Protection
Agency (USEPA) requirements for cleanup under the Superfund program. The effort will completely remove
contaminated sediments in the open water, significant permanent nearshore salmon habitat will be constructed,
and over-water shading in important marine habitat areas will be permanently removed.
In design and execution of the remedial action, Todd has elected to go beyond the minimum regulatory requirements
by fully removing the contamination from the marine environment through dredging, instead of implementing
a capping alternative that would have been acceptable to the USEPA. Additionally, Todd will exceed USEPA
requirements by demolishing three existing over-water structures, allowing permanent and complete cleanup
below these structures. Nearshore habitat to support migrating juvenile salmon will be constructed, and a
replacement pier will be constructed in a new configuration. In total, Todd will remove approximately
one acre of over-water coverage from the nearshore habitat area. These efforts provide environmental
benefits that are significantly greater than that originally required by USEPA.
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INFORMATION OUTREACH AND TRANSFER
As the largest and most productive private ship repair and production facilities in the Pacific
Northwest, Todd is dedicated to environmental stewardship both as a corporation and as a member of the Puget
Sound community. Within the company Todd is committed to educating each employee from management to craft
personnel about new pollution prevention facilities, improved Best Management Practices (BMPs) and health and
safety programs. Todd also works closely with various community organizations dedicated to maintaining and
protecting clean environments in the Pacific Northwest.
Internal Training and Employee Outreach. Todd has created specific environmental programs to ensure
that not only is the highest level of pollution prevention implemented at Todd, but that this environmental
awareness is evident at all levels of the organization. To this end, Todd created the Hazardous Substance
Control Program and the Environmental, Occupational Safety and Health Program. These programs
are designed to minimize environmental risk through policies for identifying, using, storing, disposing of and
managing hazardous substances, reporting, and alleviating workplace and environmental hazards. Employees are
trained in BMPs, pollution prevention measures, and stormwater issues, and all personnel are trained in handling,
use, disposal procedures, long and short-term risks, and emergency treatment associated with exposure to
hazardous substances. The company provides incentives to ensure and encourage employee adherence to environmental
practices.
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Community Involvement. Todd is an active member and sponsor of the Environmental Coalition of South
Seattle (ECOSS), a non-profit organization working with Puget Sound businesses and neighborhoods for an
environmentally responsible community.
Todd is also an active supporter of the Pacific Northwest Pollution Prevention Resource Center (PPRC), a
non-profit organization that is the Northwest's leading source of high quality, unbiased pollution prevention
information.
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Partnerships and Technology Transfer. In addition to implementing new pollution prevention measures,
Todd has worked to form partnerships with organizations with common goals of industry excellence and environmental
stewardship. Working closely with these organizations, Todd has been able to identify, troubleshoot, and
develop solutions for problems that exist in the shipbuilding industry on a regional and national scale.
- Puget Sound Shipbuilders Association. Todd Pacific Shipyards' Manager of Safety/Quality and Environmental Compliance,
Allen D. Rainsberger, is the current President of the Puget Sound Shipbuilders Association (PSSA). The
organization provides a network for shipyards and other marine businesses to share lessons learned on
environmental compliance, Best Management Practices (BMPs) and environmental program implementation. Regular
gatherings of the association allow safety and environmental managers to discuss issues such as stormwater
management, air quality, and hazardous material management. The PSSA currently represents 22 marine businesses.
- National Shipyard Research Program. On a national level, Todd participates in the National Shipyard
Research Program (NSRP) for both environmental and safety sectors. The NSRP, with input from wide-ranging
industry groups and organizations, has developed and published a consensus national mission and vision for
shipbuilding in the United States, which serves as a common frame of reference for collaborative, coordinated
research and development.
Working with the NSRP and the PSSA, Todd has contributed both knowledge and experience to organizations with
similar environmental issues. Through these coordinated efforts and shared experiences, Todd has learned
from other businesses to understand the various problems and solutions that the shipbuilding industry faces
each year and to increase industry-wide emphasis on environmental stewardship.
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