Saving the Future

MS4 Ordinances for Cosmetic Cleaning
BMPs & Regulations for
Mobile Power Wash Cosmetic Cleaning
10th Annual EPA Region 6 MS4 Operator Conference
July 15, 2008
Waco, Texas
by
Robert M. Hinderliter
Environmental Chairman of PWNA & UAmCc
President of RAHSCO Cleaning Systems
1-800-433-2113
Copyright ©2008, RAHSCO Cleaning Systems of Fort Worth, All Rights Reserved
Robert Hinderliter Bio
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BSME (1963) & MSME (1965) Oklahoma State University
Pilot Kansas Air National Guard and USAF (1967 to 1973)
Aircraft Engineer for Boeing and Cessna Aircraft (1963 to 1973)
Founded RAHSCOCleaning Systems (1973), a pressure washer distributor
and manufacturer
Founded Acme Mobile Power Wash (1973), a Power Wash Contract
Cleaner
Founded Power Washers of North America (www.pwna.org) (1993), a
professional trade association to address Environmental Issues.
Environmental Consultant & Instructor for Mobile Power Wash Cosmetic
Cleaning for contract cleaners, and Environmental Regulators including:
municipal, regional, state and federal.
Sponsored and organized the Fort Worth Conference on Cosmetic Cleaning
(attended by 100 Contract Cleaners and 40 Municipal, Regional, State, and
Federal regulators, July 17, 1995) that resulted in the Fort Worth Cosmetic
Cleaning Ordinance which was implemented on January 2, 1996.
Founded United Association of Mobile Contract Cleaners
(www.UAmCc.org) (2005)
Thank You
Thank you for attending this track, I know
you had 3 other tracks to chose from. I’ll
try to make your choice a wise and
valuable one.
My objective is to make sure you are
qualified to make informed choices in
developing and implementing Cosmetic
Cleaning Ordinances, BMPs, and Fact
Sheets. And to know the impact and
expected results of those choices!
Cell Phones & Pages
• Please put on:
– Silent
– Vibrate
– Turn Off
Thank You for providing
information for this presentation
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Nathan Charles, Little Rock, AR
Kathy Verhage, Albuquerque, NM
William Fordyce, Austin, TX
Martin Miller, San Antonio, TX
Louise Daniels, Dallas, TX
Barbara Bailey, Tulsa, OK
Raymond Melton, Oklahoma City, OK
Derek Johnson, Oklahoma City, OK
Geoff Brosseau, BASSMA, San Francisco, CA
Available Cosmetic Cleaning
Regulations and BMPS
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Austin, Texas
Fort Worth, Texas
Houston, Texas
Oklahoma City, Oklahoma
San Antonio, Texas
Tulsa, Oklahoma
Acronyms:
– NPDES: National Pollution Discharge
Elimination System (EPA Storm Water
Permits effecting waste water enforcement)
– MS4: Municipal Separate Storm Sewer
System (every place storm water flows)
– “Storm Drain” is not referred to as the “Storm
Sewer” to avoid confusion. Especially
important with Contract Cleaners who may
confuse the term with “Sanitary Sewer”.
– DWFS: Dry Weather Field Screen
Questions
• We have a lot of material to cover, about 8 hours
worth in 85 minutes.
• Please hold your questions until the “Question
and Answer” Period.
• Please obtain a copy of this Power Point
Presentation to make your notes and questions
on.
• Most questions will be answered in the
presentation before the end.
• 30 Minutes of Video, 35 Minutes Robert
Hinderliter Presentation, 20 Minutes Panelists
Summaries and Q&A.
Mistakes or Inaccuracies
• I’ll be covering a lot of information. Please
make notes on any disagreements,
mistakes, inaccuracies, or differences.
• These will be covered first in the “Question
and Answer” period.
DISCLAIMER
• The EPA nor any other regulating agency
approves or recommends any products,
processes, or technology of:
RAHSCO Cleaning Systems
Or
Robert M. Hinderliter
Order of the Presentation
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BASMAA Training for Contract Cleaners
(Video)
Technology & BMP Review by RAHSCO
Cleaning Systems (Video)
Note: If you understand the Technology then the
regulations & ordinances are easier to understand.
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Regulations and Ordinance Review
Ordinance Implementation Review
Panel Questions and Answers
Reality of Enforcement
What Regulators are actually enforcing.
What the results of various regulations are.
What Contract Cleaners are actually doing.
Ways to increase compliance.
Environmental History
• To understand where we are you need
know how we got here!
• Basic Structure of Environmental
Regulations
• How Regulations are implemented
• How regulations are enforced.
NPDES Permits for cities and Urban Areas
Phase I
1. Over 250,000 populations was due November 16, 1992
2. Over 100,000 populations was due October 1, 1993
Phase II
(Note: A large number of Phase I Cities received 1 year or longer
extensions of these dates)
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)
For all UA's 50, 000 to 100,000 population
For all other areas if notified by the AHJ
Getting in Step with Phase II
(Training for Regulators of Phase II
Municipalities and Urban Areas conducted
by the EPA)
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Lexington, VA April 11, 2005
Memphis, TN May 17-18, 2005
Oklahoma City, OK June 15, 2005
Indianapolis, In August 3-4, 2005
Boise, ID September 14-15, 2005
EPA 2006 Training Schedule
For Municipal and State Regulators
• Fort Worth, Texas
May 03 - May 04, 2006
• Albany, New York
May 31 - June 02, 2006
• Phoenix, Arizona
August 14 - August 15, 2006
• Lexington, Kentucky
September 21 - September 22, 2006
• And continued in 2007
EPA 2008 Training
• NPDES Training Courses and Workshops
For a current listing of NPDES Training
Courses and Workshops Google:
“NPDES Training Courses and Workshops”
Note: Webcasts include
“Training Certificates”
Phase II requires the cities (MS4s)
to implement 6 programs.
1.
2.
3.
4.
Public Education and Outreach,
Public Involvement and Outreach,
Illicit discharge detection and elimination
Construction site runoff control (one acre
and larger),
5. Post construction storm water control,
and
6. Pollution Prevention and Good house
keeping operations for the municipality.
Illicit Discharge Detection and
Elimination Minimum Control
Measures
• A storm Sewer Map
• An ordinance prohibition on non-storm water discharge
to the MS4 (Municipal Separate Storm Sewer System)
• A plan to detect and address non-storm water
discharges, including illegal dumping, into the MS4
• The education of public employees, businesses, and the
general public about the hazards associated with illegal
discharges and improper disposal of waste.
• The determination of appropriate best management
practices (BMPs) and measurable goals for this
minimum control measure.
Public Education and Outreach
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Brochures
public meeting
trade shows exhibits and presentations
newspaper inserts and articles
public notices
inserts with water and trash bills
classroom lectures
programs to neighborhood associations
Cosmetic Cleaning Ordinances
• All communities should have ordinances against
“anything but rain” down the storm drain.
• Very few Municipalities and Urban Areas have
specific Ordinances for Cosmetic Cleaning
defining BMPs and Discharge Standards for
Waste Water.
• Most Municipalities and Urban Areas have
BMPs or Fact Sheets to supplement the General
Prohibition Ordinance for Storm Drain Discharge
of “anything but rain”.
Target dates for completion are
• 1 year: Storm Sewer Map (2005 & 2006)
• 2 years: Ordinance in place (2006 & 2007)
• 3 years: A certain percentage of illicit
discharges detected and eliminated, and
household hazardous waste collection
days (2007 & 2008)
• 4 years: Most illicit discharges sources
detected and eliminated. (2008,9, & 10)
• Nearing the end of the first 5 Year Phase II
Permit.
EPA Audits
• Phase I NPDES Permit Holders will be audited
every 5 years
• Phase II NPDES Permit Holders will be audited
every 7 years.
Note: One of the causes for this schedule is that
some communities buried the EPA with data in
their NPDES Permits rather than summaries of
the data in hopes that this would avoid an audit.
So now the EPA has an audit schedule and will
start returning Permits that bury them with data.
See Nikos Singelis, with the EPA.
Phase II, Sources of Illicit
Discharges listed in table 1
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Sanitary wastewater
Effluent from septic tanks
Car wash & power washing wastewaters
Improper oil disposal
Radiator flushing disposal
Laundry wastewater
Spills from roadway accidents
Improper disposal of auto and household
toxics
Typical Power Washing
Pollution
Typical pollutants in waste washwater that
Mobile Power Wash Contractors typically
Detergents
encounter are: Herbicides
Fats
Insecticides
Oils
Pesticides
Grease
Total Dissolved Solids
Gasoline
Anti-Freeze
Solids
Emulsified Oil
Solvents
High pH levels caused by Acid Brighteners
Heavy Metals
Fertilizers
Phase II Biggest Problem
• Construction Site Runoff
– Silt
– Sludge
• The Number 1 Priority
• This means that enforcement of Cosmetic
Cleaning Waste Water Discharge
Ordinances is going to be spotty with
slowly increasing enforcement for the next
5 to 10 years!!!!!!!!!!!!!!
EPA’s Responsibilities for Stormwater discharge
The Environmental Protection Agency (EPA) does not provide
written endorsements of products, processes, or technology. The
EPA responsibilities are directed at setting specific objectives
(discharge limits) that dischargers must meet to adequately
protect receiving waters of the United States. These objectives will
necessarily vary from site to site.
If anyone tells you a product is EPA approved (like detergents) ask
to see the documentation. I have never had a company be able to
produce this documentation for routine maintenance washing. The
EPA does not have an approval process for Products, Processes, or
Technology.
EPA set the standards for cities and states thru their National
Pollution Discharge Elimination System Program (NPDES Permits).
Cities Are Responsibilities for Stormwater
Discharge Through their NPDES Permit Requirements
(National Pollution Discharge Elimination System)
Each city can decide what products, processes, and technology
they are going to use to meet EPA Guidelines.
This means the rules will vary from city to city and sometimes from
site to site within the same city. Most Metropolitan areas will have
different rules for each city!
NPDES Permit Requirement
• DWFS (Dry Weather Field Screens)
– Detergents
or
– FOG (Fats, Oil, and Grease)
My survey revealed that NPDES Permits were based on
one or the other of the above options with no
standard detection limits! This made comparisons
difficult for effectiveness of regulations.
I received everything from summaries that were easy to
understand to lots of raw data that was difficult to
interpret through an “Open Records” request.
NPDES Permits
• Phase I and Phase II NPDES Permits are
not General Permits, but are tailored to
each area. Therefore, comparison on
some items may be difficult or impossible.
Combined Total Discharge
A city is responsible for the combined total
discharge of their storm water per their NPDES
Permit. It is not uncommon for
municipalities to give exemptions to some
companies. Some (including Kitchen Exhaust)
contract cleaners have been able to get these
exemptions and discharge wash water to the
storm drains. These discharges to storm drain
have been insignificant when combined with the
total storm drain discharge of the
municipality. Note: These discharge permits
are not a release from liability for damage to
the storm drains from these discharges! If
sanitary and storm water Treatment
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. St. Louis,
Indianapolis, Sacramento, and San
Francisco are examples of cities that
treat all of their wastewater in
certain portions of the cities through
their Combined Sewer System. Most
cities go to the point source and
require remediation before discharging
to the sanitary sewer. It is
Ban Pollutants
One of the key elements of the NPDES Permit for
the municipalities requires the cities to create
and enforce an ordinance, which bans pollutant
discharges to the storm drain. The city of Fort
Worth ordinance reads: “A person commits an
offense, punishable by a fine, if he introduces or
causes to be introduced, any discharge to the
storm drain system that is not entirely composed
of Stormwater.” The EPA has granted certain
exemptions to this rule and various cities have
also enacted specific exemptions for their area.
Drinking Water Quality
• Most Municipal Environmental Regulators do not
let Mobile Power Wash Contract Cleaners
discharge to Storm Drain even if their equipment
produces “Drinking Water Quality” Discharge
Water. There are several reasons for this: 1st it
is difficult to monitor, 2nd is when discharged to
their Sanitary Sewer System they can monitor
the effluent and remediate if necessary, and 3rd
when discharging to storm drains their discharge
may become contaminated.
Reality of Enforcement
For most areas effluent discharge from mobile power washing
activities is insignificant when compared to the total storm
water discharge. Normally the Enforcement Budget has items
of more importance than power washing activities. Therefore
in most areas enforcement is done on a complaint basis only
through a Hot Line.
Very few municipalities have an officer assigned to the
enforcement and regulation of Mobile Power Washing
Activities. Unless enforcement is done on a 24/7 basis it
merely diverts this activity to nights and weekends.
Two municipalities that have full time Cosmetic Cleaning
Enforcement Offers are: San Diego, CA and Houston, TX.
Most Effective Enforcement Tool
• 24/7 “800” Hot Line
– Education
• Municipal Employees
• Businesses
• General Public
– 24/7 Monitoring
– Low Cost (very cost effective)
– For many municipalities and Urban Areas
enforcement is by “Complaint Basis” Only.
Voluntary Compliance of Environmental Regulations on
Cosmetic Mobile Power Washing
At the present time there is over 12 years of compliance history
to draw from Phase I Municipalities. The industry has proven
that there will be a high level of compliance if the regulations are:
• Logical
•Reasonable
•Rational
And if the Regulations are not logical, reasonable, and rational
there will be non-compliance on nights and weekends when
enforcement is at it lowest.
The question then becomes “How to achieve the highest level
of compliance with the least amount of expense to the
municipality and urban area?”.
Minimizing the cost of compliance
• The municipality should allow discharging
to the sanitary sewer by contract cleaners.
• This will have no impact on the POTW as
proven by over 12 years by the City of Fort
Worth, Texas.
• Fort Worth guidelines for contract cleaners
are at www.powerwash.com/regs.
Basic BMPs
Cosmetic Mobile Power Washing in the most
basic terms are:
* No off property discharge
* Directing the waste wash water to sanitary
sewer.
*Nothing down the Drain but Rain!
Cold Water Washing
In most areas cold water washing with no
chemicals is considered no worse than a rain
event. Therefore cold water washing can be
discharged to the storm drain if oil and
grease areas are precleaned, and the
discharged wash water is filtered through an
oil absorbent filter to remove any oil sheen,
and a screen to remove sand & debris.
Discharging wash
water from a sump
pump to a Sand
Trap.
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
•Note: Discharge through an Oil Absorbent
Boom or Filter.
Residential Washing
The EPA exempts residential car washing from the storm
water rules but does not address other washing activities
like house or deck washing. In most areas there is no
enforcement of the “No Off Property Discharge” rule for
house washing or deck washing and sealing. To ban
residential car washing it has to be a significant
contributor of pollutants. Generally House Washing
Waste Water should be filtered through an oil absorbent
boom then allowed to soak into the lawn for
bioremediation or discharged to the Sanitary Sewer.
It is not uncommon for the homeowner not to be required to
capture his wash water from vehicle washing but the
contract cleaner is required to capture his wash water.
Bioremediation
• When routing wash water to landscaping, check
the slope and area to be sure to avoid runoff into
a street, gutter, or storm drain. If the soil is very
dry, wet it down thoroughly before discharging
so that wash water will soak into the soil instead
of running off to the street, gutter, or storm drain.
• Michigan limits landscape discharge in the
above scenario to 1,000 gallons per month
per acre. You should also limit your
discharge to make sure that it does not reach
the ground waters through percolation.
Hot Water Washing
Detergents and Hot Water are emulsifiers. The
discharge is considered Special Waste. The
Special Waste from washing activities will
have to be added to any other Special Waste
that your customer is generating. This Special
Waste requires reporting if it exceeds a
threshold amount. The threshold amount varies
from state to state (for Texas and most other
states it is 220 pounds per month). To date I
am not aware of any contractor that has be
affected by this requirement.
The EPA does not define Hot Water. Some
regulators define it as any water that is
elevated in temperature from the tap or
outlet. This temperature can vary greatly.
Detergents and Acids
Biodegradable detergents are not OK for
discharging to the Storm Drain (Sewer).
They increase the BOD (biological oxygen
demand) of the water, which may kill living
organisms. “Biodegradable” does not mean
non-toxic.
The Regional Director of EPA Region 6 gave
me the following example: A dead horse in
a stream is biodegradable but it will kill
the stream with all of the decay! The Term
“Biodegradable” simply means that the
product will not harm bacteria in the
sewage treatment plant (POTW) and that it
breaks down faster than more conventional
Waste Water Discharge
The discharge to the Municipal Sanitary Sewer
Systems by Contract Cleaners is insignificant
when compared to the total volume that a
Municipality processes.
Usually “Hazardous Waste” cannot be discharged
to the POTW.
No off property discharge hazards: 1) soil
contamination, ground water contamination, and
air contamination. May require soil
remediation when property is sold or ground
Strom Drain Discharge
Discharge to Stormdrain should be free of
visible foam and Oil Sheen.
Discharge to surface waters must be treated
for solids removal. This can be accomplished
by filtration, or by directing wash water to a
settling basin, like a tank or low spot where
the water stops flowing.
Discharge to the storm drain should be
filtered with an oil absorbent boom or an
oil/water separator.
Contract Cleaner BMPs For Storm Drain Discharge
(currently being accepted by a majority of jurisdictions)
•Cold Water Only
•No chemicals, no visible foam
•Preclean oil and grease spots (kitty litter)
•No Oil Sheen, remediate through an oil absorbent boom
•No debris (Preclean debris [by sweeping or with a leaf
blower], filter through a 40 mesh screen or 200 micron
bag filter.
•Note: Hot water may be used in some jurisdictions for
surfaces with no oil and grease contamination.
Enforcement
If a violation occurs the Regulators may issue
citations to:
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The mobile power company
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The mobile power wash operator
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The customer’s manager
Enforcement Yoyo
• Another problem for some Environmental
Contract Cleaners is that enforcement has
been like a yoyo in some locations.
Enforcement varies from heavy to non-existent
then some customers go back to unregulated
power washing to save cost. (i.e. terminate the
Environmental Contract Cleaner)
• This is normally associated with a change of
staff or enforcement personnel.
Trivia
• Most Citations are written within a 20 mile
radius of a University.
• 95% of everything I have been teaching
has been learned from Environmental
Regulators!
• I always request that Regulating
Authorities that I consult with and help
reference me in some way. They all
agree, about 20% actually do.
Waste Water Capture
• Most Communities will accept 85 to 95%
of the Waste Water to be captured. They
will allow:
– Some leakage under Portable Dams and
Drain Covers.
– Some over-spray, like around Portable Wash
Pits (tarps) for truck washing.
– Drag-Off of Waste Water from Truck Washing
(drippage from washing)
Water Dams control the waste water for
pickup by a sump pump. The waste water
passes through a wire screen filter before
entering a holding tank. Then waste water
is discharged to a sand trap by gravity flow.
Note that there is no oil sheen after the oil absorbent booms. The vacuum
sludge filtering systems contain a bag filter and automatic discharge pump. The
vacu-boom picks up 100% of the waste water.
A Steel Eagle Concrete (Surface)
Cleaner with vacuum attachment for
recovery of the waste water. This
requires hook to both a pressure
washer and a heavy industrial
vacuum. This makes pick of the waste
water and cleaning a one step
operation.
A filter tub for cleaning kitchen grease exhaust grease filters. This job location
was for a restaurant on a barge. No waste water enter the lake. The Filter Tub
was hooked up to a Vacuum Sludge Filtering System at the bottom which
discharged the waste water to a holding tank on shore.
A water dam for storm drain sealing, an oil absorbent boom for hydrocarbon
removal, a window screen on the bottom of the sump pump for debris and sludge
removal, and a sump pump for discharge to the sanitary sewer. Legal for sanitary
sewer discharge in the City of Fort Worth, Texas for Cosmetic Cleaning.
Never discharge waste water to Storm Drains and Sanitary Sewers by
removing the covers in the middle of the streets. They are city property!
An example of a Sanitary Sewer Clean Out Port. This is private
Property and an acceptable discharge conveyance for waste water
in the City of Fort Worth, Texas.
An example of a Storm Drain Blockers
Washing on a portable tarp in 1991 for waste water capture. Note the
sump pump in the far right corner of the tarp. Every wrinkle in the tarp is a
little water dam for dropping out of the sludge and debris on the tarp which
is picked up with a plastic scoop shovel.
A child's wading pool filled with water that is higher than the surrounding
waste water will effectively seal a storm drain. It does not look
professional but is effective!
The storm drain is sealed, waste water passes through an oil absorbent boom for
removal of hydrocarbons and a window screen (around the bottom of the sump
pump) for removal of debris and sand is legal to discharge to sanitary sewer in
many jurisdictions including Fort Worth, Texas!
Many jurisdictions are accepting cosmetic cleaning waste water that passes
through an oil absorbent boom and a screen for discharge into the sanitary
sewer and storm drains!!!! Not rocket science!
A Vader I Mobile Trailer Brush Wash Rig that captures the waste water for
mobile recycling of the wash water during washing, then discharging the
waste water to a sand trap.
Note the Vacuum Boom around the helicopter for waste water capture.
An example of a Latimat Wash Pad with air berms.
An example of total recycling wash rig.
A Vacu-boom advertisement for their waste water capture systems.
An example of waste water capture for Kitchen Grease Exhaust Cleaning.
An example of waste water filtration system using commercial vacuum
cleaners. The waster water enters the top and drops through a bag filter for
debris and solids removal before automatic discharge. If an oil absorbent
boom is placed before the intake hose then the waste water will be acceptable
for many jurisdictions to be discharged into the sanitary sewer.
Houston & Fort Worth
• Houston & Fort Worth took two very different
approaches to the Cosmetic Cleaning Issue.
They represent the extremes and everyone else
fits in between. Neither is right or wrong, but are
excellent examples of reaching same goal with
almost the same results.
• Because of this I have chosen to examine these
two Municipal Ordinances and their
implementation in detail.
• RAHSCO Cleaning Systems has DVDs of
Houston and Fort Worth Conferences for
Cosmetic Cleaners available.
•July 17, 1995. A “Mobile Power Washing
Environmental Protection and Compliance
Conference” was held in Fort Worth, Texas as
part of a public comment period for a Fort
Worth Cosmetic Cleaning ordinance. The
meeting was attended by about 40 Federal EPA,
State, Regional, and Municipal Environmental
Regulators and 100 Contract Cleaner and
Industry Representatives. The conference was
sponsored by RAHSCO Cleaning System, and lead
by Robert M. Hinderliter of RAHSCO Cleaning
Systems and Brian Camp, Jr., Senior Water
Quality Specialists, Environmental
Department, City of Fort Worth. Because of
this conference Fort Worth rewrote their
ordinance and it was passed by City Council
High Lights of the Fort Worth 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 access to 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 (private property). Discharging through 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 is to displayed on each wash rig.
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.
Fort Worth Cosmetic Registration
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 Mgt
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."
What did the Fort Worth Ordinance Miss?
The best regulation for the elimination of the Yo-yo effect of
enforcement is the BASMAA “Pollution Prevention
Voucher”. This certificate should be required to be kept on file
by the Contract Cleaner and his customer for a period of three
years as adopted by Michigan Department of Environmental
Quality.
Also Michigan Department of Environmental Quality allows
discharging to ground for Cosmetic Cleaning up to 1,000
gallons per month per acre for bioremediation.
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August 22, 1996. BASMAA (Bay Area
Stormwater Management Agencies Association of
the San Francisco Bay Area) endorses CETA’s –
San Francisco Area Chapter “Mobile Cleaner
Best Management Practices for Waste Water
Runoff”. This effort was lead by Geoff
Brosseau, Executive Director, BASMAA. BASMAA
is unique in that they add a Pollution
Prevention Voucher to their program for
contractors to give to their customers.
Fort Worth Regs Effectiveness
Fort Worth Citations
• Fort Worth achieved the above results
without any citations or enforcement
actions!
• Compliance is voluntary.
Least Expensive Option
• Adopting the above regulations will
produce the highest level of voluntary
compliance with the least expense at
the highest level of compliance.
• This conclusion is based upon the survey
done for this conference and I will examine
the data in more detail.
Houston Enforcement
• Heavy Enforcement
– 6 Officers
Houston Police Department
Major Offenders Division
Environmental Investigation Unit
– Fines up to $250,000 & 5 years confinement
– Restricted (Limited) Discharge to the Sanitary Sewer.
– Literature and BMPs is available today
– Panelists will answer questions
– Contractor Training May 14, 2007.
Houston’s Results
• Houston’s Detergents in the Storm Drains
was 18 to 55% before the enforcement
effort.
• After the enforcement effort Houston’s
Detergents in the Storm Drains dropped to
2.5%!
• This is the same level that Fort Worth
reached.
Comparison of Ft Worth & Houston
• There is almost no detectible difference in
the results in the ordinances for Fort Worth
and Houston, Texas per comparison of
Detergents in the Storm Drains (DWFS).
• There is a big difference in implementation
and enforcement cost.
– Lessons to be learned for every community.
– Which of these procedures or combination of
these procedures will work best for you?
Fort Worth Summary
• Industry helped draft the ordinance, based on a
Public Comment Period with a Conference held
on July 17, 1995.
• Voluntary Compliance.
• Access to the Sanitary Sewer, all normal
Cosmetic Cleaning Activities accepted.
• Permit Based: $25.00/company + $25.00/rig per
year.
• Implemented January 2, 1996.
• No testing of waste water required, not
detectable at the POTW.
• Almost no cost to the City of Fort Worth.
Houston Summary
•
•
•
•
Training Based: May 14, 2007
Heavy Enforcement
Limited Access to the Sanitary Sewer
High Standards for BMPs, including dye
testing of portable dams and drain covers!
• Cost: 6 Major Offenders Division
Enforcement Officers (Other duties
besides Cosmetic Cleaning Enforcement)
Oklahoma City
• Similar to Fort Worth’s except:
– Require an industrial pretreatment permit.
– Limit access to Sanitary Sewer.
• This results in more detergents being
detected in the storm drains.
Oklahoma City
Dallas
• Has no Fact Sheet or BMPs for Cosmetic
Cleaners.
• Allows discharge to the sanitary sewer.
• Results not available.
Implementation of BMPs
Once you have made the choice of how you
are going to implement a Cosmetic
Cleaning Regulation these are some of the
items that will effect the interpretation &
enforcement of the Clean Water Act.
Who is an
Environmentalist?
Everybody is an “Environmentalist”! However,
how one interprets that is usually based on how
it affects their “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 home owners should not be exempt
for car washing discharge to storm sewer as
this creates a large source of pollution to our
storm sewers. This also holds true for
charities (churches, girl scouts, boy scouts,
Department Conflicts
• Stormwater/Environmental Department
says:
– No Discharge to the Storm Drain
• Sanitary Sewer (POTW) says:
– We will not accept the wastewater.
• Have never accepted this waste before.
• Do not know what we will be getting.
• Contractors will not adhere to requirements for
discharging.
• Gives the Contract Cleaners an economic
advantage over competitors.
• Require testing of every discharge and charges up
to $350.00 for each discharge.
Department Responsibilities
• What department is responsible?
– Storm Water
– Environmental
– Health Department
– Public Works
– Sanitary Sewer (POTW)
• Contract Cleaners typically get referred
from department to department without
ever getting an answer!
Silent Approval
• Some Municipalities tell the Contract
Cleaner:
– You have to be in Environmental Compliance
but we are not going to tell you what that is!
– Will not give permission to discharge to the
Storm Drain or Sanitary Sewer but will not
stop the practice at this time, acceptance by
no action.
– Will not approve Cosmetic Cleaning BMPS
but do not stop any procedure.
No Standard BMP
• There are no National Standard BMPs for
Cosmetic Cleaning.
• Metropolitan Areas typically do not have
standard BMPs.
• Dallas/Fort Worth Metroplex has about
115 Municipalities and Urban Areas and
115 separate Cosmetic Cleaning BMPs to
comply with! This is typical.
Silent Compliance
• Because of the difficulty of getting 115
separate approvals in DFW Metroplex for
Cosmetic Cleaning many Contract
Cleaners follow the Fort Worth Guidelines
in all areas without asking for approval or
permission to discharge to the Sanitary
Sewer. This is typical in all areas of the
US.
BMP Acceptance
• Troy Contract Cleaner gets his BMPs
accepted in City A.
• Troy Contract Cleaner now takes his BMP
Acceptance in City A to City B for
approval.
• City B now adds two more requirements to
City A for their approval and acceptance.
• If Troy repeats this process 10 times he is
out of business!
Contractor Practical Solution
(Risk Management)
• Follow Generally Accepted BMPs without
asking permission or approval.
• Discharging to the Sanitary Sewer and
Storm Drain following Generally
Acceptable BMPs without asking
permission or approval.
On line Training
Bay Area Stormwater Management
Agencies Association (www.basmaa.org)
has an online training video and
certification test for surface cleaners at
www.basmaa.org. See right hand column
and click on “View our 30 minute
presentation”.
www.basmaa.org
Equipment Vendors
•
•
•
•
•
Advanced Environmental Solutions, Inc.
8643 South 212th Street
Kent, Washington 98301
Phone: 800-275-3549
American Made Cleaners, Inc.
610 East Cedar
Beresford, South Dakota 57004
Phone: 605-763-5100Breg International
P.O. Box 595
Fredericksburg, Virginia 22404
Phone: 800-683-3966
Cleaning Systems Specialists
9257 Mission George Road, Suite A
Santee, California 92701
Phone: 619-488-8111
RAHSCO Cleaning Systems
2513 Warfield Street
Fort Worth, Texas 76106-7554
Phone: 800-433-2113
Environmental Cleaning Systems, Inc.
41 Shaft Road
Rexdale, Ontario M9W 4M3
Phone: 416-244-6497
• Environmental Pollution Abatement Company, Inc.
400 West Third Street, #C171
Santa Rosa, California 95401
Phone: 707-576-0202
• Environmental Process Systems, Inc.
P.O. Box 596
Mt. Holly, North Carolina 28120-0596
Phone: 704-827-0740
• Jim Manufacturing, Inc.
20 Saint Philomena Drive
Hardy, Arkansas 72542
Phone: 800-541-6299
• Geomat
P.O. Box 271852
Tampa, Florida 33688-1852
Phone: 813-936-7992Hydro-Tech Environmental Systems, Inc.
Cascade Corporate Center
175 Cascade Court
Rohnert Park, California 94928
Phone: 800-559-3102
• Jay R. Smith Manufacturing Company
P.O. Box 3237
Montgomery, Alabama 36109-0237
Phone: 800-767-0466
• Landa Water Cleaning Systems
4275 NW Pacific Rim Blvd
Camas, Washington 98607
800-547-8672
• Parker West
4520 Montecito Avenue
Santa Rosa, California 95404
Phone: 707-579-1257
• Pressure Power Systems, Inc.
P.O. Box 917
Kernersville, North Carolina 27285
Phone: 336-996-6217
• RGF Environmental Group, Inc.
3875 Fiscal Court
West Palm Beach, Florida 33404
Phone: 800-842-7771
International Phone: 0001-(561) 848-1826
Panelists Presentations
• Barbara Bailey
Environmental Compliance Specialist, City of Tulsa, Public Works /
Quality Assurance Section, 4818 S. Elwood Ave. Tulsa, OK 74107,
off: (918) 591-4384, Fax: (918) 591-4388, email:
barbailey@ci.tulsa.ok.us .
• Derek Johnson, Environmental Protection Unit Supervisor, Public
Works Department Stormwater Quality Division, City of Oklahoma
City, 420 West Main Street, Oklahoma City, OK 73102, Phone: 405297-1517, email: derek.johnson@okc.gov .
• Dorene Hancock, Section Manager, Storm Water Quality
Enforcement, Public Works and Engineering, City of Houston, 5500
McCarty, Houston, TX 77013, Phone: 713-678-5856, email:
dorene.hancock@cityofhouston.net .
Questions and Answers
• Disagreements, Mistakes, Inaccuracies, or
Differences.
• Other Questions
The End
• Thank you for your time and attention.
Robert M. Hinderliter
President
RAHSCO Cleaning Systems of Fort Worth
Environmental Chairman
PWNA & UAmCc
1-800-433-2113, or Cell: 817-366-3041
Bonus Material
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•
•
•
Houston
Tulsa
Oklahoma City
Texas Commission on Environmental
Quality
Houston, Dorene Hancock
• Houston Has 3 Enforcement Agencies
– Public Works
– Health Department
• Enforcement of Houston Ordinances
• Municipal Citation
– Houston Police Department
Major Offenders Division
• Enforce Texas Ordinances
• Criminal Prosecution
– Severity of Prosecution depends on who show up.
Houston, Dorene Hancock
• Cannot discharge Trucked Wash Water on
site. Sanitary Sewer charges are included
in the Water Bills.
• Health Department permits Trucked Wash
Water.
Tulsa, Barbara Bailey
• If heat or chemicals are added, wash
water has to be collected. No off property
discharge.
• If nothing is in the wash water, can filter
and discharge to the storm drain.
• Collect the solids, dry, and put into trash.
Oklahoma City, Derek Johnson
•
Two Agencies
– Utilities and Pretreatment
– Storm Water Quality – Enforcement
•
Requirements
– Permit for Cosmetic & Carpet Cleaners
– Follow BMP Manual
– Notify where Discharge Locations are.
•
•
Exemptions for Household Car Washing.
Can escalate enforcement with arrests.
Commentary
Polly Porter
Compliance Assistance Specialist
Small Business & Local Government Program
Texas Commission on Environmental Quality
6801 Sanger Avenue, #2500
Waco, Texas
Phone: 1-254-761-3039, Fax: 1-254-772-9241
Texas Commission on Environmental Quality,
Polly Porter
• 3 elements of Cosmetic Cleaning
– Public Education
– Enforcement
– Disposal
• After precleaning do spot cleaning of heavy oil
and grease spots.
• For Industrial Sites that require a SWPPP you
will have to include the waste water discharge
that goes to landscaping in your plan.
Texas Commission on Environmental
Quality, Polly Porter
• Charity Car Washes should partner with
Stationary Car Washes for charity events
so that the discharge can be captured.
• Very large amounts of discharged cold
water to the storm drains can be
hazardous because of chlorine content.