Management of Wash Water Runofffrom Pressure Washing and Vehicle Detailing

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BMPs for Containment/Disposalfor

Charlotte and Mecklenburg County 

byRobert M. Hinderliter

Environmental Consultant, United Association of Mobile Contract Cleaners5055 Business Center Drive, Suite 108 ~ #225,Fairfield, CA 94534

Toll Free: 1-800-816-3240, Mobile: 707-812-3702www.uamcc.org, www.pressurewashingnews.com

President, Delco Cleaning Systems of Fort Worth2513 Warfield Street, Fort Worth, Texas 76106-7554

Phone: 800-433-2113, Fax: 817-625-2059www.dcs1.com , www.pressurewash.com

Note: The opinions and information presented on the above websites do not necessarily represent the opinions, guidance and regulations of the City of Charlotte or Mecklenburg Co.

Edited by

Craig Miller, QEP, Senior Water Quality Specialist Charlotte Mecklenburg Stormwater Services

600 East 4th St., Charlotte, NC  28202

Phone:  (704) 336-7605, Fax:  (704) 336-6586, Email:  cmmiller@ci.charlotte.nc.us Note: The products and/or methods shown or depicted in this seminar may be covered by U.S. Letters of Patent.Copyright 2009, Delco Cleaning Systems of Fort Worth, All Rights Reserved

Thank You

• UAMCC wishes to express our appreciation to the City of Charlotte and Mecklenburg County 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.

Clean Water Act

Nothing Down the Drain But Rain

Basic Rules of the CWA & other federal law •The CWA prohibits a point source discharge of pollutants into waters of the US without a proper permit.

•If your discharge wash water does not reach waters of the US, you significantly reduce your liability 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 US should be fishable and swimmable.

Terminology1. 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 spoil, 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 Storm Drain System that is not composed entirely of storm water, with some exceptions.

10. FOG: Fats, Oil, Grease

Your interaction will most likely be with local regulators, but you are still liable to state and federal government law

and enforcement.

Federal

State

Municipality

The regulating line of authority is:

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) - 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

• Charlotte is a Phase I Municipality

• Phase II Co-Permittees: Mecklenburg County, Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville

• Other Phase II Municipalities in the area:

Belmont, Concord, Cramerton, Dallas, Harrisburg, Hemby Bridge, Gastonia, Indian Trail, Kannapolis, Marvin, Monroe, Lowell, McAdenville, Mt. Holly, Ranlo, Stallings, Weddington, Wesley Chapel, Cabarrus Co, Gaston Co, Union Co

Every permitted municipality is required to establish and enforce a local stormwater pollution control ordinance to prevent illicit discharges into the storm drain system.

They’re 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 didn’t have the time and resources to focus on small businesses, but local agencies do (and they’re required to).

Why so much attention on our industry recently?

Cities/Counties Are Responsible for Stormwater Discharge 

Each city decides what products, processes, and technology 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!

Charlotte-Mecklenburg plans to work with other local Phase II municipalities to hopefully adopt a seamless set of policies and guidance.

Authority Having Jurisdiction (AHJ)

Where wash water is discharged determines what regulatory agency you must deal with. Discharge locations are: 

• Groundwater/Land

• Surface Water (creeks, lakes, etc.)

• Sanitary Sewer or the POTW

• Private or Commercial Disposal Facility 

Charlotte-Mecklenburg Contacts

• City of Charlotte Storm Water Services, Craig Miller, (704) 336-7605

• Mecklenburg County Storm Water Services, Rusty Rozzelle, (704) 336-5449

• Charlotte-Mecklenburg Utilities, Regina Cousar, (704) 336-4962

Charlotte Mecklenburg Hotline

• 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:

DetergentsFatsOilsGreaseGasolineSolidsSolventsHeavy Metals

HerbicidesInsecticidesPesticidesAntifreezeEmulsified OilHigh pH levels caused by Acid BrightenersFertilizers

This photo was taken on April 3, 2009 and shows the storm drain near the Speedy Truck Wash where Metropolitan Sewer District of Louisville, KY claims that waste from washing pig trucks was sent. (from the Courier-Journal.com)

What wastes generated by Mobile Contract Cleaners may be hazardous waste?

• Oil Saturated Absorbents

• Wash water containing:o Solvent Cleanerso Fats (haz in some states)o Oil (haz in some states)o Grease (haz in some states)o Total Dissolved Solidso Heavy Metalso Pesticides/Herbicides/Insecticideso Paints Chips contains lead, mercury, chromium, cadmiumo Lead from battery washing or engine degreasingo High pH levels caused by acid brightenerso Asbestos contamination from insulation, shingles, sidingo Antifreeze

Mobile Contract Cleaners should avoid Hazardous waste if at all possible because POTWs generally do not accept hazardous waste and it’s expensive and burdensome to dispose of elsewhere.

BMPs for Containment

• Rules and guidelines for Charlotte-Mecklenburg• Suggested options on how to comply (including best practices and equipment)

Pre-cleaning with dry methods

If a “dry” wash method is used, no wastewater 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 absorbent (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, 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 (more current) example of a wash water recovery pad for vehicle and equipment washing

Simple Recovery Mat

Plastic Tarp, Shop Vac

Achieving compliance does not necessarily mean expensive. Be innovative!

NOTE!!!!!Simply buying and “displaying” equipment does not mean compliance. You must use it properly.

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 mainly 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 (Interior of trailers and tankers) should be limited to non-hazardous, inert and biodegradable materials.

A Portable Dam sealing off a storm drain, and a sump pump with a window screen filter .

Portable dams and mats

Portable Mat to seal off drain. Use mats with magnets and/or place heavy object on top to ensure good seal. Check throughout job to ensure 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. Does not give a real 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

• You could damage the pipe. Inflatable drain plugs are capable of exerting a lot of 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 4 vacuum connections on top of the surface cleaner. The pressure washer trigger gun hooks ups up at the top left of the picture just out of view.

Some commercially available equipment

Surface Cleaner RecoveryTool hooked up to a TruckMounted 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.

Drape kitchen exhaust to capture wash water. Note the plywood and plastic sheeting protection of the ranges and fryers.

Cleaning of Kitchen Exhaust Equipment

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 draining wash water by gravity flow into the grease trap, which is connected to the sanitary sewer.

Draping for a roof fan cleaning. Wash water collected in a portable basin.

BMPs for Disposal

• Rules and guidelines for Charlotte-Mecklenburg• Suggested options on how to comply (including best practices and equipment)

Off property Discharge Liabilities1. Surface Water Contamination

2. Groundwater/Soil Contamination

Based on these liabilities, the following disposal options from Mobile Contract Cleaning are encouraged (when legal to do so):

• No off property discharge

• Directing the waste wash water to:o Sanitary sewer (in accordance with all rules & regs)

• On site• Hauling off site

o Private Environmental Facility

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. Charlotte-Mecklenburg Utilities goes 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• Specific rules about volumes, pre-treatment requirements and

discharge limits will be covered in presentation later.

• 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.

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 disposalDischarge wastewater to Sanitary Sewers as this is the most economical location. If it is not available, then discharge 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 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

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 through a 200 Mesh screen or smaller.

• To remove hydrocarbons filter through an oil absorbent filter or 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). Like bringing the pH within acceptable limits. Disposal options:

• Discharge to Sanitary Sewer

• <100 gal/day: no permit or notification required; pre-treatment highly encouraged

• Less than 1,000 gal/day: no permit or notification required, but pre-treatment is required (in order to meet discharge limits)

• Over 1,000 gal/day: permit required.

• Hauling to proper disposal location

• Storing for controlled release of less than 1,000 gallons/day.

• 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

• Amount and type of remediation often depends on volume and nature of wash water. Your job is to find the most cost-effective method that still achieves compliance with rules.

• Contracts often go to whoever can capture and dispose of the wash water in the least expensive, yet compliant, manner.

• Simple/inexpensive: mesh screens; oil absorbent pads, booms & pillows; existing underground oil/water separators, grease traps, sand traps and clarifiers

• Other more costly systems, but may be necessary: Vacuum Systems with Filtration; Pretreatment Units; Limited Recycling Units; Total Recycling Units; flocculation; absorbing media, etc.

•Mobile Power Wash Recycling units do not remove: Detergents, dissolved solids, heavy metals, pesticides, solvents, antifreeze, emulsified oil & grease.

•The longer you recycle with the same water the dirtier (more contaminated) it will become.

•If you recycle long enough wash water may become hazardous waste. You will then need to have a “Hazardous Waste Haulers Permit” and 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 purge their recycle units of wastewater and refill 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.

Mobile Power Wash Recycle Units

Discharges to Landscaped Areas:• In most cases, for structures or surfaces surrounded by landscaping,

wash water that naturally drains into it is allowed

• Exceptions are typical heavily polluted surfaces like parking lots and restaurants

• You may not collect wash water and dispose of it directly into landscaping. It may contaminate soil/groundwater, damage landscaping, and lead to all sorts of wastewater being dumped on ground. Also, NC State Code does not allow it.

Discharges to the Storm Drains• Discharges containing detergents or chemicals cannot go to

Storm Drains;

• Washing with cold water and no 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.)

• Pass discharge through mesh screen and 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 storm drain, means >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

• Locally, Haz Mat Transportation & Disposal will accept the wastewater and has a fee structure set up specifically for such wastes. Located at 221 Dalton Ave., Charlotte; (704) 332-5600

A Word about “Biodegradable” & “Green” 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 can be more easily processed by the POTW (sewer treatment plant). These products are preferable for discharge to sanitary sewer versus 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 entering 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 by complaint basis only will have little effect on stopping this waste water from entering storm drains.

• 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 are receiving 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.

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 to capture, control, and clean wash water with.

UAMCC’s Comments

• The BMPs are– Rational– Reasonable– Logical

• The sales of Environmental Equipment are not Regulatory Driven.

• The Contract Cleaner can choose the level of investment from $300 - $3,000 – $15,000 depending on his choice to maximize his profits.

The End

• Thank you for your time and attention

Robert M. HinderliterEnvironmental Consultant UAMCCCell: 817-366-3041Email: robert@dcs1.com