Hinderliter-Cosmetic.. - South Central Chapter of IECA

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Management of Wash Water Runoff
from Pressure Washing and Vehicle Detailing
BMPs for Containment and Disposal
for
EPA’s Cosmetic Cleaning
Model Ordinance
at
http://www.epa.gov/nps/ordinance/documents/FortWorthSW.pdf
Courtesy of
Power Washers of North America
&
United Association of Mobile Contract Cleaners
Version 8-3-2011
Cell Phones and Pagers
• Please put them on:
– Silent
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Preface
This is a model presentation for regulatory agencies
to use when holding “Public Comment Periods,”
“Training Seminars for Contractors and
Regulators,” and “Cosmetic Cleaning” Ordinances.
You are free to pick, choose, and modify slides as
you wish. All that PWNA & UAMCC asks is that
credit be given to PWNA & UAMCC for using
this guide, and that you forward your BMPs and
Ordinances to the PWNA & UAMCC.
by
Robert M. Hinderliter
Environmental Chairman of PWNA & UAMCC
Office: 817-529-6601, Cell: 817-366-0341,
robert.hinderliter@powerwash.com
Power Washers of North America
PO Box 270634, Saint Paul, MN 55127
Toll Free: 1-800-393-7962, Fax: 651-762-2961, E-mail: info@pwna.org
Environmental Committee Members: Charlie Arnold ( revca@mchsi.com); Eric Clark
(eclark@britewash.net); Paul Horsley (paul@scottspressurewash.com); Mike Hilborn
(mikeh@rooftodeck.com)
United Association of Mobile Contract Cleaners
Address: 314 Marlow Court, Chesapeake, VA 23322
Toll-Free Phone: 800-816-3240, Email: info@uamcc.org
Board of Directors: Michael Tessaro (centexpw@gmail.com); David Vicars
(aplus_pressurewashing@yahoo.com); John Orr (john@exteriorcleaning.com);
Randy Bario (pantheroutdoor@gmail.com); Russ Spence
(russ@prokleenpressurewashing.com)
Note: The products and methods shown or depicted in this seminar may be covered by
U.S. Letters of Patent.
Copyright 2011, Power Washers of North America & United Association of Mobile
Contract Cleaners , All Rights Reserved
Background
After completing a national survey of Cosmetic Cleaning
Environmental Regulations, the EPA chose the
ordinance developed in cooperation with the City of
Fort Worth as a model for other municipalities and
urban areas to follow. Some of the reasons for this
were:
1. The ordinance is reasonable, rational, and logical.
As such, the ordinance is good for the city of Fort
Worth, the contract cleaner, and the environment.
2. The ordinance has been based on voluntary
compliance since January 2, 1996.
3. Almost no cost to the city of Fort Worth.
Background
4.
5.
6.
7.
After the ordinance was adopted, it resulted in one
of the lowest discharge rates of detergents into
storm drains in the nation.
Meets the EPA NPDES Permit Limits.
The Fort Worth ordinance is based on a Public
Comment Period with a conference held July 17,
1995 with approximately 100 contract cleaners and
40 regulators representing municipal, county,
regional, state, and federal EPA regulators. This
conference is posted on YouTube as
“EPAPowerWashing” for your free viewing.
The Fort Worth ordinance is posted on the EPA’s
website as a model ordinance for other
municipalities.
Thank You
• The PWNA & UAMCC wishes to express
our appreciation to the various
municipalities for their willingness to work
with the industry in developing these BMPs.
• This workshop is the initial step in the
process. Additional forums for discussion
will take place over time.
Vendors Recognition
• Would vendors please introduce themselves
at this time and make themselves available
for questions and answers at the end of this
workshop?
Reality of Enforcement
What regulators are actually enforcing.
What the contract cleaner actually needs to know.
What contract cleaners are actually doing.
How contract cleaners can be profitable.
Who is an
Environmentalist?
Everybody is an “environmentalist”! However,
how one interprets that is usually based on how
it affects his or her “economic revenue stream”
(income, wages, business revenue). An
environmental regulator brought this
information to my attention.
Example: A large segment of the “Coin-op car
wash industry” believes that homeowners should
not be exempt from car wash discharge draining
to the storm sewer since this is a large source
of pollution in our storm sewers. This also
holds true for charities (churches, Girl
Summary of
EPA’s Model Ordinance
Best Management Practices
for
Management of Wash Water Runoff
from Pressure Washing and Vehicle Detailing
www.epa.gov/nps/ordinance/documents/FortWorthSW.pdf
EPA’s Model Ordinance BMPs
•
(1) Always Pre-clean: do not discharge
sand, dirt, and debris into the sanitary
sewer or storm drain.
–
–
Clean up debris and dispose of it properly
(sweeping, leaf blower, vacuum, etc).
Pre-clean oil and grease spots with an oil
absorber and dispose of it properly. Collect
oil and grease accumulations for proper
disposal.
• (2) Always Filter Waste Water
A. To remove silt, sand, sludge, and debris,
filter the waste water through a 200
mesh screen or smaller.
B. To remove hydrocarbons, filter the
waste water through an oil absorbent
filter or oil/water separator (oil
absorbent boom, recycling system, sand
trap, grit grease trap, clarifier, etc).
Wash Water Capture
• 1st Choice - Use a permanent pad to capture
the wash water.
– A permanent pad is typically made of concrete
and is designed for washing vehicles while
preventing wash water from reaching a storm
drain.
• 2nd Choice - Use a portable pad to capture
the wash water.
Wash Water Capture
• 3rd Choice - Seal the storm drains and
capture the wash water with a vacuum
system, sump or other technology.
– The type and technology of the system is the
responsibility of the contract cleaner.
Wash Water Capture
• 4th Choice - Evaporation is acceptable as long as
the evaporation occurs on property and on a
surface that will not absorb contaminants. After
the surface has dried the contaminants need to be
swept or vacuumed up so that when it rains the
contamination will not be washed away. If the
surface is a gravel or porous surface, the water
table must be at such a depth where the
groundwater will not be polluted. Check with
your local municipality.
Discharge to the Sanitary Sewer Preferred
• Discharging to the sanitary sewer is allowed
with a Cosmetic Cleaning permit.
– Some cities require a permit others do not.
Contact your Public Works department for your
city's requirements. The Public Works
department may need to direct you to another
department.
Discharge to the Sanitary Sewer Preferred
• Discharge must be in compliance with local
regulations and limits (solids - less than 250 mg/L,
petroleums - less than 250 mg/L), and may require
pre-treatment, sampling, and possibly other
measures.
– This will depend on the municipality.
– The city of Fort Worth has never been able to detect
wash water from cosmetic cleaning in their POTW
(Publicly Owned Treatment Works).
Discharge to the Sanitary Sewer Preferred
• Ensure pH of the wash water is between 5.0
and 12.0 (use pH test strips) and below
150˚F.
– These limits are typically above those for
normal cosmetic cleaning waste water.
Discharge to the Sanitary Sewer Preferred
• Filter using the best available method that
removes the largest amount of contaminants.
– Sand trap, grit trap, grease trap, or clarifier.
– If these options are not available, then discharge the
waste water to a mop sink, utility sink, kitchen sink,
toilet, inside floor drain, or sanitary sewer clean-out
stub.
– Never remove the sanitary sewer or storm drain
manhole cover as these are city property and require
authorization to open.
Discharge to Landscape Areas 2nd Choice
• For discharges to landscape areas you must do the
following:
– Obtain the property owner’s permission.
– Ensure discharge volume is small enough that it soaks
into the ground without running off the property. Limit
your discharge to 1,000 gallons/acre per month.
• On property, wash water discharge can only occur
on the property where the wash water is generated.
Discharge to Landscape Areas 2nd Choice
• Do not discharge repeatedly to the same
landscape area because doing so may
contaminate soil and groundwater, damage
plants, and cause other nuisance conditions.
Discharge to Landscape Areas 2nd Choice
• Off property discharge can cause serious harm to
groundwater.
– Contract cleaners that are near a body of water in cities
such as San Francisco, Miami, and Fort Lauderdale can
contaminate ground water. As a general rule, the water
table needs to be 50 feet down depending on your type
of soil.
– For example, if building a fence in your area results in
hitting ground water, the water table is high and
discharging would pollute the groundwater. It is
important to check with your local municipality
regarding regulations.
• Ensure pH of the wash water is between 6.0 and
9.0 by using pH test strips.
Recycled Wash Water - 3rd
Choice
• If the wash equipment being used recycles
the water for reuse, the following may
apply:
– All discharge locations are to be reported to the
Sanitary Sewer Department in advance of
discharging wash water.
– Recycled wash water typically must be tested
annually and the results reported to the Sanitary
Sewer Department as required.
Recycled Wash Water - 3rd
Choice
• Recycling wash water concentrates the
contaminants and pollutants. The POTW
(Publicly Owned Treatment Works) does not
typically accept concentrated waste water. If the
waste water is recycled long enough, the pollution
becomes hazardous waste. There is a continuous
buildup of the total amount of dissolved solids,
heavy metals, and detergents. This then requires
the contractor to have a hazardous waste haulers
permit.
Discharge to Storm Drains - not
recommended
• Never discharge detergents, chemicals, or
hot water to storm drains.
• Washing with cold water (less than 110°F)
and no chemicals is considered no worse
than a rain event and may be discharged to
storm drains for surfaces that do not have
oil, grease, or other contaminants.
Discharge to Storm Drains - not
recommended
• Water that is greater than 110°F is
considered hot water and considered the
same as using soap.
– Hot water is an emulsifier and similar to using a
detergent.
• Discharges must be free of foam and oil
sheen.
– An oil sock will remove foam and oil sheen.
Discharge to Environmental
Waste Company
• It is generally acceptable to capture the
wash water and dispose of it through an
environmental waste company.
Additional Information
Discharge Limits
• If pH limits are too high, then the use of
batch processing (holding tank) may be
necessary in order to add water to dilute the
wash water to obtain acceptable pH levels.
– This may not be allowed in some
municipalities.
• Another option if pH levels are too high is
to add an acid to neutralize the wash water.
Discharge Limits
• Flocking may also be an option. Flocking is the
adding of a chemical that separates and binds
pollutants together so they either drop to the
bottom or float to the surface. The cleaned water
can then be discharged to the Sanitary Sewer. The
flocked pollutants are stored in a drum until an
environmental waste hauler can pick it up for
proper disposal
– More popular with stationary cleaners.
Biodegradable Detergents
• Use biodegradable, non-toxic, phosphate-free
detergents when practical.
• Biodegradable does not mean non-toxic, it only
means that it can be easily processed at a sanitary
sewer plant. It does not mean that it can be
discharged to the storm drain.
• Phosphates act like fertilizers causing moss and
algae to grow in lakes, rivers and streams,
depleting oxygen levels and killing fish and native
vegetation.
Drought Conditions
• Potable Water - depending on the drought
restrictions in your area, the local potable
(drinking) water supply may be restricted for
power washing except for health and safety
reasons.
• When power washing for health and safety
reasons, permission is required in advanced from
the Health or Environmental departments.
Gray Water
• Power washing with gray water (nonpotable water) is acceptable.
– Permission in advance is required from the
Health or Environmental departments.
• Trucked-in Potable Water is acceptable.
– Permission in advance is required from the
Health or Environmental departments.
Liability
• Discharging to landscaping, sanitary sewers
or storm drains under these guidelines is not
a release of liability to the contractor or
customer if clean up or remediation is
required.
Local Municipality
• Each Sanitary District you discharge your wash
water to has jurisdiction over what criteria you
must meet to discharge your wash water to their
storm drain or sanitary sewer. That means that if
you are in a metropolitan area with dozens of
municipalities, you have to comply with each
cities’ set of guidelines. In order to solve this
problem, some contract cleaners have chosen to
capture all of their wash water and haul it to a
disposal site, like their own sand trap.
Local Municipality
• Municipalities do not have to follow the
EPA’s Model Ordinance. Most
communities will modify these BMPs for
their local environmental requirements.
Job Specific BMPs
Transportation Related
Washing examples
Fleet Washing - Exterior Only
• To remove dirt and hydrocarbons, with or
without soap, storm drain disposal is not
permitted. The wash water must be
discharged to landscaping or the sanitary
sewer. Some unavoidable evaporation will
occur on paved surfaces.
Fleet Washing - Exterior Only
• Preferred - use wash pads to capture the wash water and
discharge it to the sanitary sewer.
• Ideally, the customer has established a separate wash area
that captures wash water.
• Or, contract cleaners can use a temporary wash pad and
pump the discharge to the sanitary sewer.
• If the wash area is a paved surface, seal storm drains and
rinse this surface after washing and rinsing each vehicle.
• If a significant amount of wash water runoff evaporates at
the site before it can be collected, and the site is routinely
used for this purpose, the paved area itself must be
cleaned.
• The wash water must be collected and discharged to the
sanitary sewer.
Fleet Washing - Exterior Only
• 2nd Best - direct wash water to landscape
or dirt area.
– Wash water should be discharged to a
landscape or dirt area sufficiently large enough
to contain all the wash water. Discuss this with
the property owner.
Engine/Equipment Degreasing
• Auto/truck drive train cleaning, engine
degreasing and airplane cleaning including
landing gear.
– With or without soap, no storm drain disposal
permitted.
– Requires pretreatment before discharge to
sanitary sewer.
– Should be cleaned on a wash pad.
Acid Cleaning of Unpainted
Trucks/Containers
• Trucks and metal containers (unpainted)
using acid cleaners.
– No storm drain disposal permitted.
– The runoff from cleaning unpainted trucks or
containers with acid cleaners must be
neutralized to a pH between 6 and 10 before
discharging to the sanitary sewer.
Mobile Auto Detailing
• Infrequent, light cleaning, using soap rarely at the same site; removing mainly dirt
with minimum water volume.
Mobile Auto Detailing
• Preferred - minimal runoff may remain on paved
surfaces to evaporate.
– If wash water will reach the storm drain, seal the storm
drain and discharge the wash water to the sanitary
sewer.
• 2nd Best - direct wash water to landscape or dirt
area.
– Wash water should be discharged to a dirt or landscape
area sufficiently large enough to contain all the wash
water. Discuss this with the property owner.
Car Lot Rinsing for Dust Removal
• Rinsing dust from exterior surfaces using
water only, no soap or solvent.
– If the vehicle or vehicles have been previously
washed with a soap or solvent following BMPs,
then it is acceptable to rinse the vehicles with
just water and allow it to discharge to a storm
drain.
• To reduce dust, clean the cars first, and then rinse
with water only.
Car Lot Rinsing for Dust Removal
• Wash water should be discharged to a
landscape or dirt area sufficiently large
enough to contain all the wash water.
Discuss with the property owner.
• Prevent contamination of the runoff by not
allowing it to run through oil deposits on
the pavement or gutter.
Semi-Trailers
• Truck trailer, non toxic, food related,
interior cleaning.
– Sweep, collect and dispose of debris. Use dry
cleaning methods as much as possible.
– Food residue must be properly filtered.
• Filtered contents are disposed of as garbage.
– Wash water cannot be discharged to the storm
drain but must be discharged to the sanitary
sewer.
Boat Cleaning
• Filtered wash water must be discharged to
the sanitary sewer.
• Do not allow wash water to enter the lake,
river, bay, ocean, etc.
• Dispose of paint particles appropriately.
• These BMPs do not address the disposal of
paint.
Surface Cleaning examples
Sidewalks and Plazas - using soap
and/or hot water
• Sweep, collect, and dispose of debris.
• Wash water must go to the sanitary sewer.
• The BMPs in this section do not apply if
there has been an oil or other hazardous
material spill on the site. In the case of a
hazardous spill, contact the local fire
department for guidance.
Sidewalks, Plazas, Driveways,
Drive-thru Window areas with light oil, frequently
cleaned - no soap
Sidewalks – Continued
• Sweep, collect and dispose of debris.
• Dry clean oil spots and properly dispose of debris.
• Place oil absorbent boom or oil sock around storm
drain.
• Wash water may go to the Storm Drain through an
oil absorbent boom and screen.
• No oil sheen can be visible on the water flowing
into the Storm Drain.
Drive-thrus, Driveways, Service
Stations with excess oil deposits,
not frequently cleaned with or
without soap
• Sweep, collect and dispose of debris.
• Dry clean oil spots with an absorber and
dispose of properly.
• Seal storm drains and discharge wash water
to the sanitary sewer.
Building Exteriors, Walls, House
Washing, Roof Cleaning - without
soap
• Sweep, collect and dispose of debris.
• Dry clean oil spots and properly dispose of debris.
• Place oil absorbent boom or oil sock around storm
drain.
• Wash water may go to the storm drain through an
oil absorbent boom and screen.
• No oil sheen can be visible on the water flowing
into the storm drain.
Building Exteriors, Walls,
House Washing, Roof Cleaning
- with soap
• Preferred - seal storm drain, discharge
wash water to the sanitary sewer.
• 2nd Best - direct wash water runoff to dirt
or landscape areas.
Painted building, with paint
job in good shape - no soap
used
• Built after 1977. For structures built before 1978,
see the EPA’s lead abatement program. These
BMPs do not address this issue. (google: “lead paint
certification” for classes in your area)
• Preferred - pre-clean, seal storm drain, discharge
wash water to the sanitary sewer.
– Dispose of collected particles as garbage.
• 2nd Best - pre-clean then direct wash water runoff
to dirt or landscape areas.
Painted buildings, to remove
paint and clean in preparation
of painting - with or without
soap
• These BMPs do not address the disposal
of paint.
Graffiti
Graffiti Removal - using wet sand blasting or
high pressure washing with cleaning
compound.
– Minimize quantity of water used.
• Preferred - pre-clean, seal storm drain,
discharge wash water to the sanitary sewer.
• 2nd Best - pre-clean then direct wash water
runoff to dirt or landscape areas.
Kitchen Exhaust Cleaning
• With or without soap, storm drain disposal
is not permitted.
• Large amounts of grease should be
collected and put into the grease dumpster
or disposed of by an environmental waste
company.
• Wash water disposed to the grease trap.
Parking Garages
- with excess oil deposits, not frequently
cleaned - with or without soap
• Sweep, collect and dispose of debris.
Note: This may be hiring a street sweeper to do the
initial cleaning.
• Dry clean oil spots with absorbent and
dispose of properly.
• Seal Storm Drains and discharge wash
water to the “Sanitary Sewer”.
Parking Garages Continued
Terminology:
• Sand Trap means some type of remediation for dirt, sand,
debris, and hydrocarbons
– Common names are: Oil/Water Separator, Clarifiers, Sand Traps,
inceptors, etc.
• AHJ: Authority Having Jurisdiction, which is going to be
where you discharge your waste water to:
– Sanitary Sewer Department
– Storm Drain (MS4) Departments.
Parking Garages Continued
First off, to bid this type of job you need to look at
the Architect Blue Prints and have a walk through
with the inspector of the Sanitation Department to
determine the following (in some cases the
Sanitation Department will have plans which are
more accurate and marked in conjunction with
Google Maps):
Parking Garages “Walk Through” Continued
• Where the Sanitary Sewer lines are, how they are
identified or marked, and their flow capacity that
is available for your waste water discharge. Note:
if you exceed the capacity of Sanitary Sewer Lines
you can stop up the plumbing and have multiple
over flows of commodes on several floors!
• Where the Storm Drain lines are, how they are
identified or marked, and their flow capacity that
is available for your waste water discharge.
Parking Garages “Walk Through” Continued
• What type of remediation system is at the bottom
of the structure: is it a sand trap, Oil/Water
Separator, sand/dirt filter, or nothing? You will
find all types of remediation systems; newer
buildings may have extensive remediation system
like a sand trap or other advanced technology
while older buildings may discharge everything
directly to the storm drain (MS4).
Parking Garages “Walk Through” Continued
• If there is a water collection system at the bottom
of the structure, where does it discharge to?
Sanitary Sewer or Storm Drain (MS4).
• What sort of containment technology exists in the
structure? Was it built with Power Washing taken
into consideration?
Parking Garages “Walk Through” Continued
• Often Parking Garages are attached to loading
docks. These will probably be covered to stop the
entry of Storm Water with a Sand Trap installed
leading to Sanitary Sewer. A lot of building
managers do not know where these discharges
go. Sometimes this takes up to a week to find out,
but you have to know.
Parking Garages “Walk Through” Continued
• After all of the above have been determined, you
need to contact the Sanitary Sewer or Storm Drain
(MS4) Departments about discharging to them
through the building collection system if it exists,
and determining what additional remediation may
be required.
• If the structure has not been designed properly
then you will have to determine the best way of
capturing your wash water for proper disposal.
Parking Garages “Walk Through” Continued
• If the EPA’s Model Ordinance has been adopted
then all that is required is Precleaning and
Filtration as explained in the first two
PWNA/UAMCC BMPs, and determine the best
way to capture your wash water for discharge to
sanitary sewer.
Parking Garages “Walk Through” Continued
• Where the waste water is discharged to will be the
AHJ on the amount of remediation required. It
can be as simple as oil absorbent booms and a
sand filter to highly technical equipment costing
over $100,000.00. These units have very large
filtration capacity because of the large amounts of
pollutants and debris found in multi-story parking
garages. Your filtration system has to have the
capacity to handle your discharge volume.
Parking Garages Continued
After all of the above have been accomplished, you
are finally ready to figure time and materials and bid
the job.
PWNA & UAMCC
Certification Course
• This information is provided as a courtesy
of the PWNA & UAMCC and is available
as a PWNA or UAMCC Certification
Course to members.
Other Resources
• Another good training resource is
www.basmaa.org. This website includes a
Cosmetic cleaning instructional training video and
online certification test with certificate.
• A video on how a POTW (Publicly Owned
Treatment Works) plant operates is available at
http://www.youtube.com/watch?v=D1aABVbI4JE
Background Information
for
the Development of Regulations and BMPS
1972 Clean Water Act
Nothing Down the Drain But Rain
Basic rules of the CWA and other federal laws
•The CWA prohibits a point source discharge of pollutants into the waters of the U.S.
without a proper permit.
•If your discharge does not reach waters of the United States, then there are no
requirements under the CWA. No off property discharge if possible.
•The Generator is responsible for “cradle to grave” of his waste.
•Private citizens can sue the government or other private citizens for violation of the
CWA.
•The EPA does not approve products, processes, or technology, but sets specific
discharge objectives that dischargers must meet.
•The CWA says that you cannot dilute your discharge with water to achieve
discharge limits.
•EPA established a national goal that all waters of the U.S. should be fishable and
swimmable.
Typical Exemptions
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
water line flushing
landscape irrigation
diverted stream flows
rising groundwater
uncontaminated groundwater infiltration
uncontaminated pumped groundwater
discharges from potable water sources
foundation drains
air conditioning condensate
(commercial/residential)
irrigation waters
springs
water from crawl space pumps
footing drains
lawn watering
residential and charity car washing
flows from riparian habitats and wetlands
dechlorinated swimming pool discharges
street wash water
flows from emergency fire fighting
Terminology
1. The EPA is very specific when it comes to classifying waste wash
water: “Waste Wash Water is considered a source of Industrial
Waste.”
2. “Process Water” means any water, which during manufacturing or
processing, comes into direct contact with or results from the
production or use of any raw material, intermediate product, finished
product, byproduct, or waste product.
3. “Pollutant” means dredged soil, solid waste, incinerator residue,
filter backwash, sewage, garbage, sewage sludge, munitions,
chemical wastes, biological materials, radioactive materials, heat,
wrecked or discarded equipment, rock, sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water.
4. AHJ: Authority Having Jurisdiction.
5. POTW: Public Owned Treatment Works (Sewer Plant).
6. MS4: Municipal Separate Storm Sewer System (Storm Sewer System. Includes
storm sewer pipes, street, gutters, and drain ditches along the highway if they empty
into waters of the state.)
7. BMP: Best Management Practices means schedules of activities, prohibition of
activities, maintenance procedures, and other management practices to prevent or
reduce pollution of the MS4 and waters of the US. BMPs also include treatment
requirements, operating procedures, and practices to control plant site runoff, spillage
or leaks, sludge or waste disposal, or drainage from raw material storage.
8. Cosmetic Cleaning means cleaning done for cosmetic purposes. It does not
include industrial cleaning, cleaning associated with manufacturing activities,
hazardous or toxic waste cleaning, or any cleaning otherwise regulated under federal,
state, or local laws.
9. Illicit Discharge: Any discharge to a storm drain system that is not composed
entirely of storm water, with some exceptions.
10. IDDE: Illicit Discharge Detection and Elimination.
11`. FOG: Fats, Oil, Grease
EPA Sets the Standards
The regulating line of authority is:
Federal
State
Municipality
Contract cleaners will most likely interact with local
regulators, but they are still subject to state and federal
government law and enforcement.
EPA recognized that our waters were
being contaminated by stormwater runoff
•EPA took control of the situation
through their National Pollution
Discharge Elimination System Program
(NPDES Permits) – and set the
standards for cities and states
•For the first time business, industry, and government bodies became
responsible for pollution washed off their property by rainwater
•The program was implemented in two phases for municipalities
•Phase I in 1993 – cities >100,000 population
•Phase II in 2004 – smaller urban areas > 100,000 population
Phase II
For Urban Areas whether incorporated or unincorporated
were due March 10, 2003, (a 5 year plan was required,
filings were done 2003, 2004, & 2005, EPA conducted
training 2005 & 2006 for regulators, delayed due to 9th
Circuit Court of appeals ruling).
Most jurisdictions are in their second 5-year plan which
required an IDDE, Illicit Discharge Detection and Elimination,
Program which includes:
•Car wash & power washing wastewaters
•Laundry wastewater
Why so much attention on our industry recently?
Every permitted municipality is required to establish and
enforce a local storm water pollution control ordinance to
prevent illicit discharges into the storm drain system.
They are also required to have a hotline for citizens to report
pollution and violations.
This is why local oversight and enforcement has become
more frequent and why mobile contract cleaning has
received more attention. State and federal agencies focused
on bigger industries and problems. They did not have the
time and resources to focus on small businesses, but local
agencies do (and they are required to).
Cities/Counties Are Responsible for Stormwater
Discharge
Each city decides what products, processes, and technologies they
are going to use to meet EPA guidelines.
This means the rules will vary from city to city. Most metropolitan
areas will have different rules for each city.
Most Phase II Jurisdictions (Municipalities, Counties, etc.) plan to
work with other local Phase II Jurisdictions to adopt a seamless set of
policies and guidance.
Authority Having Jurisdiction (AHJ)
Where wash water is discharged determines what regulatory agency
has oversight. Discharge locations are:
• Groundwater/Land
• Surface water (creeks, lakes, etc.)
• Sanitary sewer or the POTW
• Private or commercial disposal facility
Local Municipal Contacts
• Storm Water Services, Mr. Regulator, (705)
338-7602 <Insert your local number>
• Health Department, Mrs. Regulator, (705)
335-5442 <Insert your local number>
• Environmental Department, Mr.
Environmental, (705) 335-4966 <Insert your
local number>
Local Hotline
• Hot Line: 800-xxx-xxxx
• Non-Emergency Hotline 311
goes to City/County
Customer Service, which
refers environmental calls to
the appropriate agency for
investigation.
Typical Pollution from Mobile Contract
Cleaning
Typical pollutants in waste wash water that Mobile Contract
Cleaners generate are:
Detergents
Fats
Oils
Grease
Gasoline
Solids
Solvents
Heavy Metals
Herbicides
Insecticides
Pesticides
Antifreeze
Emulsified Oil
High pH levels caused by Acid Brighteners
Fertilizers
Gasoline Explosion
Gasoline is the number one source of explosions in sewer
systems. One gallon of gasoline when vaporized and
mixed with air, has the same explosive force as 14 sticks
of dynamite.
This photo was taken on April 3, 2009 and shows the storm
drain near the Speedy Truck Wash where the Metropolitan
Sewer District of Louisville, KY claims that waste from
washing pig trucks was sent. (from the Courier-Journal.com)
Find & Eliminate Pollution Sources
The Problem
How many pollution sources can you find?
Hazardous Waste
The waste stream can also be greatly affected
by the season. For example, in the winter it
is common to apply salt, sand, or other
deicing materials to the roads.
Mobile power wash cosmetic cleaners need to
avoid hazardous waste if at all possible
because POTWs generally do not accept
hazardous waste.
Avoid Hazardous Waste
Many contractors limit their operations to
cosmetic cleaning and avoid:
•degreasing
•two-step chemical cleaning
•aluminum brightening
•battery cleaning
•washing of chemical trucks that may
produce hazardous waste.
Treated wood shingles are often treated with a
toxic material and should be dry cleaned only.
Runoff from cleaning may be toxic to plants in
a landscaped area and should never be
Used Oil
The EPA has classified used oil (hydrocarbons) as nonhazardous if it is destined for
•recycling
•refining
•reprocessing
•burning for energy recovery
Therefore, you should dispose of your used oil in one of the
aforementioned ways.
Hazardous Waste
It should be noted that the states of California, Arizona,
Massachusetts, Minnesota, Missouri, New Jersey, New
York, Rhode Island, South Carolina and Vermont
regulate used oil as a hazardous waste.
Special Waste
Some states designate used oil as a special waste and have
rules more stringent than those of the EPA, these are
Arizona, Illinois, Maine, Michigan, Minnesota,
Washington, Wisconsin, and Wyoming. Also some
counties have even more rules concerning used oils.
What Wastes Generated by Mobile
Contract Cleaners may be Hazardous
Waste?
• Oil Saturated Absorbents
• Wash water containing:
–
–
–
–
–
–
–
–
–
–
–
–
Solvent Cleaners
Fats (hazardous in some states)
Oil (hazardous in some states)
Grease (hazardous in some states)
Total Dissolved Solids
Heavy Metals
Pesticides/Herbicides/Insecticides
Paint Chips containing lead, mercury, chromium, cadmium
Lead from battery washing or engine degreasing
High pH levels caused by acid brighteners
Asbestos contamination from insulation, shingles, siding
Antifreeze
Hazardous Waste
Mobile contract cleaners should avoid
hazardous waste if at all possible because
POTWs generally do not accept hazardous
waste and it is expensive and burdensome to
dispose of it elsewhere.
There is a relationship that we do
not like to think about
EVERYTHING is recycled sooner or later.
Pollution prevention is the best way so that
we keep pollutants out of the cycle from the
beginning.
BMPs for Containment
• Rules and guidelines for typical jurisdiction
• Suggested options on how to comply (including best
practices and equipment)
Pre-cleaning with dry methods
If a “dry” wash method is used, no waste water is generated, so
there is no discharge that would require a permit under the CWA.
Always Pre-clean: In some cases you can eliminate the need to
collect wash water if you follow this process:
•Use absorbents (such as rags, absorbent mats or pads, rice hull
ash, cat litter, vermiculite, sand, and Oil Sorb) to pick up greasy
or oily spots.
•Sweep or vacuum to pick up litter, debris, and saturated
absorbents.
•Properly dispose of absorbents and debris (in vast majority of
cases – bag it and place in regular trash).
Wash Water Control Devices – some examples
Sump pumps; wet/dry Vac with and without sump pumps; vacuum
sludge filtering systems; Vacu-Booms; portable dams; drain covers;
portable vinyl wash pits; portable vinyl wash pads; surface cleaners
with vacuums attached for water capture; plumbers drain plugs; sand
bags; rubber mats; temporary berms; and water dikes.
An oil absorbent boom before a vacuum boom with a portable dam
after the vacuum boom to catch accidental discharges. The oil
absorbent boom removes the oil sheen and free oil and grease. Note
the oil sheen before the oil absorbent boom.
November 1991. Dan and John Cassello in Connecticut start washing
Coca-Cola Trucks on a canvas tarp over a vinyl tarp.
Berms on the side were made of PVC sewer pipe and rolled up
tarp across the ends. Note the sump pump in the far right hand
corner. The canvas trap was very heavy when wet.
Another (current) example of a wash water recovery pad for
vehicle and equipment washing
Simple Recovery Mat
Achieving compliance does not
necessarily mean expensive. Be
innovative!
NOTE!!!!!
Simply buying and “displaying”
equipment does not mean
compliance. You must use it
properly.
Plastic Tarp, Shop Vac
An example of waste
water capture and
proper disposal.
Not Rocket
Science!
Think,
Imagine,
Conceive,
Action
Vehicle/Truck/Fleet Washing
For truck washing, evaporation, absorption and drag-off
normally account for 20 to 50% of water loss, depending on
how warm the ambient temperature is.
After washing is accomplished, the wash area should be
cleaned to prevent dirt, sludge, and debris from being washed
into the storm drain when it snows or rains.
The washing of hauling compartments (interiors of trailers and
tankers) should be limited to non-hazardous, inert, and
biodegradable materials.
Portable dams and mats
A Portable Dam sealing off a storm drain, and
a sump pump with a window screen filter .
Portable Mat to seal off drain.
Use mats with magnets and/or
place a heavy object on top of it
to ensure good seal. Check
throughout job to ensure there is
no leakage underneath.
As long as the water in the child’s wading pool is higher than the
wash water on the outside of the wading pool, it will seal off the
storm drain. Note the window screen around the bottom of the
sump and oil sock to filter out debris, sand, and oil. It does not
present a very professional image, but it works!
Drain Plugs
Installing a “Drain Plug” in municipal
sewer systems to contain wash water
is highly discouraged and not allowed
by some municipalities because:
•You could damage the pipe. Inflatable
drain plugs are capable of exerting
extreme force.
•You may seriously injure yourself.
Catch basin grates are very heavy.
•You may injure others. If you
accidentally drop a grate into a catch
basin, car accidents may occur.
Storm Drain Filters
Many companies are
now making products
similar to this.
A screen and oil absorbent booms
have been installed before the drain.
Booms will help remove oil, grease
and some debris. A mesh screen
provides added debris filtering.
A 24-inch vacuum recovery
surface cleaner. Note the four
vacuum connections on top of
the surface cleaner. The
pressure washer trigger gun
hooks up at the top left of the
picture just out of view.
Some commercially available equipment
Surface Cleaner Recovery
Tool hooked up to a truck
mounted carpet cleaner
A portable vacuum “tube”
hooked to a wet/dry vac
Note the berm for wash water containment and the sump
pump pit in the lower left hand corner of the wash pad.
Cleaning of Kitchen Exhaust Equipment
Drape kitchen exhaust to capture wash water.
Note the plywood and plastic sheeting
protection of the ranges and fryers.
Draping for a roof fan cleaning. Wash water
collected in a portable basin (Filter Tub).
Power washing grease exhaust filters in a filter tub. A
grate in the tub’s bottom filters out grease/debris. Note
the drain hose at the bottom of the tub which is draining
wash water by gravity flow into the grease trap, which is
connected to the sanitary sewer.
BMPs for Disposal
• Rules and guidelines for typical jurisdiction
• Suggested options on how to comply (including best
practices and equipment)
Off-Property Discharge Liabilities
1. Surface Water Contamination
2. Groundwater/Soil Contamination
Based on these liabilities, the following disposal options for
mobile contract cleaning are encouraged (when legal to do
so):
• No off property discharge
• Directing the waste wash water to:
 Sanitary sewer (in accordance with all rules and
regulations)
 On site
 Hauling off site
 Private Environmental Facility
Combined Sewer System
Separated Sewer System
Restaurants
Medical
Automotive
Sewer Lines
Residential
Interference with Plant
Treatment System
Educational
Industry
Religious
Treatment
Plant
Stream leads back to water
supply
Municipalities may or may not treat their Storm Water
Cities can either treat all of their sanitary and storm water
or go the point source of the pollution and require
remediation before discharge to sanitary sewer.
Most municipalities go to the point source and require
remediation before discharging to the sanitary sewer. It is
significantly less expensive to require point source
remediation than to remediate the pollution at their POTW.
Discharges to the Sanitary Sewer
•
POTWs are designed to handle domestic sewage and similar
wastewater, not industrial wastes containing chemicals, metals,
oil, etc. They cannot remove all contaminants.
•
Discharges must be in compliance with local regulations and
limits, and may require pre-treatment, sampling, permitting
and/or other measures.
•
The total volume of wastewater generated by all cosmetic
contract cleaners is insignificant when compared to the
municipalities total treatment capacity.
So, we can treat it (most of the
time!) but….
• Wastewater Treatment infrastructure is
built to handle domestic
sewage…anything that is of greater
strength than domestic sewage requires
more effort to remove… and may not
come out!
Lateral Line Care – Remember who has to fix it
CMU is responsible for
repairs in this area
Cleanout
One line
shown
Cleanout
Sanitary sewer discharge locations: Utility sinks, clean-outs, inside
floor drains, commodes, sinks, and clean-out stubs which are
connected to the Sanitary Sewer.
Sanitary sewer cleanout port
Indoor utility basin
Some POTWs have “Trucked Wastewater Disposal Sites” to received “Trucked
Wastewater”. These sites may be at the POTW or remote locations.
You have to make the phone calls in your market area (survey) to see what your
disposal options are.
On-site disposal
Discharge wastewater to sanitary sewers as this is the most
economical location. If it is not available, then discharge it to a
commercial waste disposal facility.
The trailer contains a waste water holding tank and filter cleaning
tub. The wastewater was hauled to a disposal site on location away
from the lake.
For kitchen exhaust and restaurant cleaning, collected grease
should be disposed of into a grease container (grease dumpster if
available), and the waste water into the grease trap.
Check with the chef to make sure this is acceptable.
Grease Dumpster (Not to be confused with a Trash Dumpster)
Discharging into Manholes is strictly forbidden, no matter where
they are located. It is not only dangerous to remove the lid from a
manhole but it is also illegal in most cities. Manholes are city
property!
Caution
Do Not Remove Sanitary or Storm Sewer Manhole Covers
•
Always Filter Waste Water: To remove silt, sand, sludge, and
debris, filter the water through a 200 Mesh screen or smaller.
•
To remove hydrocarbons filter through an oil absorbent filter or an
oil/water separator.
•
Use remediation methods and discharge conveyances that remove
the most amount of contamination:
Sand traps, grease traps, oil/water separators, clarifiers which are
connected to the sanitary sewer. They are located at: Truck washes, coin-op
car wash bays, automatic car washes at gas stations, restaurants, and various
other businesses. Use the following if the aforementioned are not available:
Utility sinks, clean-outs, inside floor drains, commodes, sinks, and
clean-out stubs
•
Obtain the permission of the “discharge location owner” who is
probably the waste generator before discharging your used wash
water on the job site. For kitchen exhaust cleaning this would be
the chef.
•
Discharge Limits: If satisfactory discharge limits cannot be
reached with continuous waste water flow, then use batch
processing (holding tank). For example, when bringing the pH
within acceptable limits. Disposal options include:
•
Discharge to the sanitary sewer

Normal cosmetic cleaning waste water is within
acceptable limits.
•
Hauling to proper disposal location
•
Biodegradable: Use biodegradable, non-toxic chemicals if
possible. Note: Biodegradable does not mean non-toxic, it
only means that it can be easily processed at a sanitary sewer
plant. It does not mean that it can be discharged to the storm
drain.
Remediation Methods continued
• The amount and type of remediation often depends on the volume
and nature of the wash water. Your job is to find the most costeffective method that still achieves compliance with rules.
• Contracts often go to whomever can capture and dispose of the
wash water in the least expensive, yet compliant, manner.
• Simple/inexpensive: mesh screens; oil absorbent pads, booms and
pillows; existing underground oil/water separators, grease traps,
sand traps, and clarifiers.
• Other more costly systems, but ones that may be necessary
include: vacuum systems with filtration; pretreatment units; limited
recycling units; total recycling units; flocculation; absorbing media;
etc.
Mobile Power Wash Recycle Units
•Mobile Power Wash Recycling units do not remove: detergents, dissolved solids,
heavy metals, pesticides, solvents, antifreeze, emulsified oil and grease.
•The longer you recycle with the same water, the dirtier (more contaminated) it
becomes.
•If you recycle long enough, wash water may become hazardous waste. You
will then need to have a “Hazardous Waste Haulers Permit” and will need to
dispose of your wash water as “Hazardous Waste.” You can no longer discharge
to the Sanitary Sewer.
•Most contract cleaners limit their recycling to 1 or 2 days, then they purge their
recycling units of wastewater and refill them with fresh water. This avoids the
hazardous waste problem and produces a better quality wash. Wash with recycled
water and rinse with fresh water.
•Recycling units that deliver “Drinking Water Quality” discharge are very
expensive and are not currently economical for Mobile contract cleaners.
Recycled Waste Water
•
•
All discharge locations are to be reported to the
Sanitary Sewer Department in advance.
Recycled waste water must be tested annually and
the results reported to the Sanitary Sewer
Department as required.
Discharges to Landscaped Areas:
•
In most cases, for structures or surfaces surrounded by landscaping,
wash water that naturally drains into it is allowed.
•
For low polluted surfaces, not for heavily polluted surfaces like
parking lots and restaurants.
•Obtain the property owner’s permission
•Preclean and filter the waste water
•You may collect wash water and dispose
of it directly into landscaping.
•No off-property discharge
•pH waste water is between 6.0 and 9.0
•General limits: 1,000 gallons/acre/month
Discharges to the Storm Drains
•
Discharges containing detergents or chemicals cannot go to storm
drains
•
Washing with cold water and without chemicals may be
discharged to storm drains for surfaces that are not contaminated
with oil and grease (such as parking lots, sidewalks, etc.)
•
Common cold water jobs: sidewalks, driveways, building
exteriors, homes, fences, plaza areas, car lots
•
Always pre-clean oil and grease spots (kitty litter) and debris
(sweeping, leaf blower, etc.)
Underground storm water detention/retention by Cultec, Inc.
These underground retention ponds are not remediation devices
for cosmetic cleaning wastewater but are for flood and
sediment control.
Common cold water jobs
•Car lots (cars are to be clean before being
placed on the lot)
•sidewalks
•shopping malls
•buildings exteriors
•homes
•parking lots
•garages
Kitchen grease exhaust cleaning is NOT a
common cold water job. Any type of oil and
grease cleaning is a common Hot Water job.
Discharges to the Storm Drain
• Pass discharge through a mesh screen and an oil absorbent
to remove debris and oil/grease.
•Discharges should be free of visible foam and oil sheen.
•Hot water, for purposes of discharge to a storm drain, is water
with a temperature >110F.
Discharges to Environmental Waste Company:
•
It is always acceptable to capture the waste water and
dispose of through an Environmental waste company.
•
Generally the most expensive option.
•
Local Environmental waste companies are:
• XXXXXXXXXXXX <Insert your local companies here>
• XXXXXXXXXXXX
<Insert your local companies here>
A Word about “Biodegradable” Products
• Biodegradable detergents are not OK for discharging to the storm
drain. They increase the BOD (biological oxygen demand) of the
water, which may kill living organisms. “Biodegradable” does not
mean non-toxic.
• Biodegradable generally means that it is more easily processed by
the POTW (sewer treatment plant). These products are preferable for
discharging to a sanitary sewer rather than other products.
Waste Management
•Waste generator, which is your customer, is owner of the waste from
cradle to grave. Talk to your customer about who is going to be
responsible for solid wastes generated from a job.
•The least expensive method of collecting your dirt, sand, and debris
is right off of your wash surface before it enters your wash water
pumping equipment. A $20.00 broom and shovel is an inexpensive
method of picking up dirt and debris.
Cost & Benefits of Compliance
• There is going to be a cost associated with the control of discharged
contract cleaning waste water.
• Enacting regulations prohibiting the discharge of contract cleaning waste
water to storm drains with enforcement through a complaint basis only will
have little effect on stopping this waste water from entering storm drains.
• The biggest benefit in compliance is doing your part in cleaning up the
environment and avoiding fines.
• Mobile power wash operators who invest time, money, and equipment to
offer environmental washing services receive a big competitive advantage.
It is not unusual for these operators to double or triple their business in a
year. Since they are the only ones with an approved procedure, guess who
gets recommended. Of course, this exclusive position will only last until
someone else gets approval, but by that time you should have already
established your reputation.
Enforcement
If a violation occurs the Regulators may issue
citations to:
•
The mobile power wash company
•
The mobile power wash operator
•
The customer’s manager
Available Remedies
•
•
•
•
•
•
Notice of Violation
Compliance Agreement
Compliance Order
Cease and Desist Order
Suspension
Termination
•
•
•
•
Civil Penalties
Public Notice
Criminal Violation
Remedies Nonexclusive
Process for How We
Address Violations
Step 1: Violation Observed
or Reported
 Many
discharges are reported by
citizens or other local government
employees through a central hotline
(311) or our website.
 Some are observed by
environmental specialists while doing
field work.
*NOTE: We do not “patrol” the streets
looking for violators. We do not have
the time and resources available to do
so.
Step 2: Investigate Alleged Violation
 Environmental
specialists from Environmental
Department/Storm Water Services investigate the alleged
violation.
The investigation process includes:
o Speaking with the person alleged to be in violation
o Observing discharge area, storm drain system, surface
waters
o Taking pictures, video
o Obtaining additional info (violator’s name, address, etc.)
o Explain findings to person alleged to be in violation
(educate)
o Document all findings in writing
Step 3: If Violation Confirmed…
A violation is confirmed through physical evidence (observe discharge in person,
observe stains/wet pavement, pictures/video, samples, etc.). Violation is not
typically confirmed solely through a citizen’s report – it needs accompanying
evidence.
Issue verbal Notice of
Violation (NOV)
1st offense (non-willful)
Issue written NOV
1st offense (willful)
Issue written NOV
Issue
penalty
2nd or continuing offense
Issue written NOV
Apply other enforcement
remedy
Violator must clean up impacted area and submit
written response describing corrective actions
What does a Notice of Violation say?
• Location and nature of violation
• General description of enforcement remedies
and penalties that may apply
• Specific actions needed to correct the violation
and restore impacted area
• Deadline to complete corrective actions
• How to provide additional information to the
regulatory agency
• Contact name and information
• Requires written response explaining corrective
actions
Monetary Penalties Examples
Maximum Penalties
• Charlotte - $5000 per day per violation
• Mecklenburg Co. - $10,000 per day per violation
• Davidson - $5000 per day per violation
• Matthews - incremental depending on history (maximum $1000 for 1st;
$2000 for 2nd; $3,000 for 3rd; etc.)
All penalties collected go to the public school system, not Storm Water
Services.
Large penalties are reserved for bad violations – really large volumes,
hazardous chemicals, long history of violations, uncooperative, etc.
All “mitigating and aggravating factors” are considered: (1) degree and extent
of harm, (2) whether committed willfully, (3) whether reasonable measures
were taken to comply, (4) voluntary measures to clean up and report, (5) prior
record, etc.
Our aim – to make penalty amounts consistent with the severity of violation
and to make non-compliance more expensive than compliance.
Examples of Other Enforcement Remedies
• Withholding
of permit, certificate of occupancy or other approval
• Compliance Agreement
• Compliance Order
• Cease and Desist Order
• Emergency Relief
• Injunctive Relief (court order)
Appeals (example)
• All ordinances have an appeals process
• The Storm Water Advisory Committee (SWAC) hears the appeals
• SWAC is made up of nine citizens who are nominated and then appointed by
the County Commission, City Council and Town Councils
• SWAC bylaws have specific requirements for committee representation
Makeup
o 1 member from industry, manufacturing, or commercial sector
o 1 member from environmental organization
o 1 member who is a construction contractor
o 1 member from financial, accounting or legal profession
o remaining members appointed from a cross section of the community
Appointments by Area
o 3 by Charlotte Council
o 3 by County Commission
o 1 by Northern Towns
o 1 by Southern Towns
o 1 by other 8 committee members
The Cost of
Noncompliance
Should NOT be less
than the Cost of
Compliance
Environmental Management - System Protection
Ink or Dye
Copper
Soap
Window Cleaner
Inspectors in Action
If we cannot resolve it, it is time to call
the lawyers – please call us or come by
to see us before this happens!
What does the future hold?
For power wash contractors of the 21st Century,
water management will be as important as the
pressure washing.
You will now have to have a toolbox full of
tools for proper water management. Just as a
carpenter has more than a hammer in his tool
box, it will be necessary for the pressure wash
contractor to have more than one type of device
for capturing, controlling, and cleaning wash
water.
EPA’s Model Ordinance Cosmetic Cleaning
BMPs Continued
High Lights of the Fort Worth (EPA’s Model) Code:
DIVISION 2, COSMETIC CLEANING
A discharge or flow of cold water used in cosmetic cleaning that is
not contaminated with any soap, detergent, degreaser, solvent,
emulsifier, dispersant or any other cleaning substance may be
discharged to the storm drain as long as the storm drain inlet is
screened to catch debris and the discharge passes through an
oil absorbent pad or boom. No oil sheen may be present in the
discharge after it passes through the pad or boom. Screen the
storm drain inlet with a 20 mesh or finer screen to catch the
debris.
The total volume of wastewater generated by all the cosmetic
cleaners operating in Fort Worth on any given day was not
likely to exceed 20,000 gallons; this volume is "insignificant"
when compared to the City's total treatment capacity.
The Cosmetic cleaner was given to access the sanitary sewer
The waste water belonged to the property owner, not the
cosmetic cleaner, so the waste water should be discharged onsite if possible. The ideal discharge point would be into a sand
or grit trap such as those found in car wash bays. Unfortunately,
few sites contain such facilities so the discharge options revert
to sinks, toilets, floor drains and clean-out stubs while using a
400 micron filter to remove the grit and sludge.
It is up to the property owner to decide which conveyance to
discharge into as they own the plumbing system located within
their property lines.
Discharges into manholes are strictly forbidden, no matter
where they are located (city property).
Cosmetic Cleaners that utilize wash water recycling units fit into
"process water" category and must test their effluent at least once
annually.
$50.00 Permit Fee for first Wash Rig
The fee for the permit (which goes to the business) is $25.00.
The fee for the registration certificates is $25.00 per wash unit.
Preclean liquid accumulations of oil or grease with absorbent clay
or a similar material prior to washing. The oil soaked clay should
be placed in a plastic bag and disposed to a dumpster.
Discharges to the sanitary sewer must not have a temperature
greater than 150° F, must not have a pH less that 5.0 or greater
than 12.0.
Offenses are punishable by a fine of up to $2,000 per day per
offense.
Hot water is defined as any water over 110°F.
Discharges to the storm drain using hot water cosmetic
cleaning without any chemicals are approved provided that
permission is granted by the Depart of Environmental
Management prior to using the hot water. This exemption was
designed for cosmetic cleaners washing objects such as
sidewalks, headstones, walls and other things that are unlikely to
be affected by the normal pollutants such as oil and grease.
Mobile commercial cosmetic cleaning means "power washing,
steam cleaning, and any other mobile cosmetic cleaning
operation, of vehicles and/or exterior surfaces, engaged in for
commercial purposes."
Links to the Fort Worth Code:
City of Fort Worth:
http://www.fortworthgov.org/DEM/powerwash.htm
EPA Model Ordinance:
http://www.epa.gov/owow/nps/ordinance/documents/Fort
WorthSW.pdf
Michigan Department of Environmental Quality
http://www.deq.state.mi.us/documents/deq-ead-taspowrwash.pdf
The following is a more technical
way of presenting the BMPs
which may be preferred by some.
It the same information presented
differently and covers a wider
range of situations.
3. Discharges to Environmental
Waste Company
• It is always acceptable to capture the waste
water and dispose of it through an
environmental waste company.
4. Discharges to the Sanitary
Sewer
• Discharges to the Sanitary Sewer (as indicated by
a “Yes” in the table below) are allowed with a
Cosmetic Cleaning Permit. All other discharges
are either not allowed or prior approval is required
from the Sanitary Sewer Department. Discharges
must be in compliance with local regulations and
limits (solids <250 mg/l, Total Petroleum <250
mg/l), and may require pre-treatment, sampling,
permitting and/or other measures. Ensure pH of
the waste water is between 5.0 and 12.0 (use pH
test strips) and below 150° (normal cosmetic
cleaning waste water).
5. Discharges to the Storm Drains
• Never discharge detergents or chemicals to the
storm drains.
• Washing with cold water (<110°F) and without
chemicals is considered no worse than a rain event
and may be discharged to the storm drains for
surface that are not contaminated with oil and
grease.
• Discharges should be free of visible foam and oil
sheen.
6. Discharges to Landscaped Areas
For discharges to landscaped areas (as indicated by “Yes” in
the table below) you must do the following:
(a) Obtain the property owner’s permission.
(b)Ensure discharge volume is small enough that it soaks into
the ground without running onto paved areas. Generally,
limit your discharge to 1,000 gallons/acre/per month,
collect waste water on property for distribution on
property where discharge occurs - no off property
discharge.
(c) Do not discharge repeatedly to the same areas because
doing so may contaminate soil/groundwater, damage
plants, and cause other nuisance conditions.
(d) Ensure pH of the waste water is between 6.0 and 9.0 (use
pH test strips).
EPA’s Model Ordinance Cosmetic Cleaning BMPs
Washing
Activity
Conditions
Storm
Drain
Sanitary
Sewer
Landscaped
Area
Environmental
Waste
Company
Comments
Cold Water,
No
Chemicals,
auto rinsing,
homes,
decks, side
walks,
buildings
To remove
mainly dirt,
surfaces
without oil
and grease
YES
See item #5
YES
See item
#4
YES
See item #6
YES
See item #3
Preclean any
oil and
grease spots
if any.
Hot Water,
No
Chemicals,
auto rinsing,
homes,
decks, side
walks,
buildings
To remove
mainly dirt,
surfaces
without oil
and grease,
no
chemicals,
with heat
YES
See item #5*
See
comments at
right
YES
See item
#4
YES
See item #6
YES
See item #3
* May
discharge to
the storm
drain with
prior
permission
from
CharlotteMecklenburg
Utilities
EPA’s Model Ordinance Cosmetic Cleaning BMPs
Washing
Activity
Conditions
Storm
Drain
Sanitary
Sewer
Landscaped
Area
Environmental
Waste
Company
Comments
Hot Water
Chemicals
Trucks,
autos,
homes,
buildings, flat
work,
machinery,
aircraft, trains
To remove
mainly dirt,
and light
amounts of
oil and
grease
No
Yes
See item
#4
YES
See item #6
YES
See item #3
These items
are not
normally
contaminated
with heavy
amounts of oil
and grease.
Hot Water
Chemicals
Trucks,
autos,
homes,
buildings, flat
work,
machinery,
aircraft, trains
To remove
mainly dirt,
and heavy
amounts of
oil & grease
No
Maybe*
See item
#4
No
YES
See item #3
Collect oil and
grease
accumulation
s and dispose
of properly, as
with oil filters
EPA’s Model Ordinance Cosmetic Cleaning BMPs
Washing
Activity
Conditions
Storm
Drain
Sanitary
Sewer
Landscaped
Area
Environmental
Waste
Company
Comments
Hot Water
Chemicals
Degreasing
of Engines,
Equipment,
5th Wheels
To remove
large
amounts of
grease
No
No
No
YES
See item #3
Collect oil and
grease and
dispose of
properly, as with
oil filters and to
an
Environmental
Waste
Company
Hot Water
Chemicals
Kitchen
Grease
Exhaust
Cleaning
No
Yes
See item
#4
No
YES
See item #3
Large amounts
of grease
should be
collected and
put into the
grease
dumpster or
disposed by an
environmental
waste company;
waste water
disposed to the
grease trap.
EPA’s Model Ordinance Cosmetic Cleaning BMPs
Washing
Activity
Conditions
Storm
Drain
Sanitary
Sewer
Landscaped
Area
Environmen
tal
Waste
Company
Comments
Acid
Cleaning –
Metal or
Masonry
To remove
metal oxides
(Aluminum
Brightening)
or Mineral
Deposits
(Masonry
Building
Restoration)
YES
See item #5 Prior
permission
required from the
Environmental
Department.
Maybe See
Item #4,
Prior
permission
required
from the
Sanitary
Sewer
Department
Maybe See
Item #6, Prior
permission
required from
the
Environmental
Department
YES
See item #3
Neutralize
wastewater,
use oil/heavy
metals
absorbent
booms
PWNA& UAMCC’s Comments
• The BMPs are
– Rational
– Reasonable
– Logical
• The sales of environmental equipment are not
regulatory driven, but compliance driven in order
to protect the environment.
• Contract cleaners can choose the level of
investment from $300 - $3,000 – $15,000
depending on their choice to maximize their
profits.
The End
• Thank you for your time and attention
• Robert M. Hinderliter
Environmental Chairman PWNA & UAMCC
Cell: 817-366-3041, Off: 817-529-6601
• Email: robert.hinderliter@powerwash.com
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