management of wash water runoff from pressure washing and vehicle detailing bmps for containment and...
TRANSCRIPT
Management of Wash Water Runofffrom Pressure Washing and Vehicle Detailing
BMPs for Containment and Disposalfor
EPA’s Cosmetic CleaningModel Ordinance
athttp://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– Vibrate – Turn Off
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.
byRobert M. Hinderliter
Environmental Chairman of PWNA & UAMCCOffice: 817-529-6601, Cell: 817-366-0341,
Power Washers of North AmericaPO Box 270634, Saint Paul, MN 55127
Toll Free: 1-800-393-7962, Fax: 651-762-2961, E-mail: [email protected] Committee Members: Charlie Arnold ( [email protected]); Eric Clark ([email protected]); Paul Horsley ([email protected]); Mike Hilborn ([email protected])
United Association of Mobile Contract CleanersAddress: 314 Marlow Court, Chesapeake, VA 23322
Toll-Free Phone: 800-816-3240, Email: [email protected] of Directors: Michael Tessaro ([email protected]); David Vicars ([email protected]); John Orr ([email protected]); Randy Bario ([email protected]); Russ Spence ([email protected])
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. After the ordinance was adopted, it resulted in one
of the lowest discharge rates of detergents into storm drains in the nation.
5. Meets the EPA NPDES Permit Limits.
6. 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.
7. 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 Scouts, Boy Scouts, etc). Because of political activity by the Coin-Op Car Wash Association (with a $500,000.00 budget) the San Diego Regional Water Quality Control Board banned charity washing during February of 2001.
Summary of
EPA’s Model Ordinance
Best Management Practices
for
Management of Wash Water Runofffrom 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 (non-potable 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 & UAMCCCertification 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 groundwaterdischarges 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
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 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
Contract cleaners will most likely interact with local regulators, but they are still subject to state and federal
government law and enforcement.
Federal
State
Municipality
EPA Sets the StandardsThe 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) – 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
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).
Why so much attention on our industry recently?
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:
DetergentsFatsOilsGreaseGasolineSolidsSolventsHeavy Metals
HerbicidesInsecticidesPesticidesAntifreezeEmulsified OilHigh pH levels caused by Acid BrightenersFertilizers
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.
Gasoline Explosion
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?
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.
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 discharged to the storm drain or sanitary sewer.
Used OilThe EPA has classified used oil (hydrocarbons) as non-hazardous 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 There is a relationship that we do not like to think aboutnot 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
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, 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.
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 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 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 which is 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 (Filter Tub).
BMPs for Disposal
• Rules and guidelines for typical jurisdiction• 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 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
Stream leads back to water supplyTreatment
Plant
Restaurants
Medical
Automotive
Interference with Plant Treatment System
Sewer Lines
Residential
Industry
Educational
Religious
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.
Municipalities may or may not treat their Storm Water
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 (So, we can treat it (most of the most of the time!time!) but….) 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 itLateral Line Care – Remember who has to fix it
CMU is responsible for repairs in this area
Clean-out
Clean-out
One line shown
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 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 cost-effective 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 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.
Mobile Power Wash Recycle Units
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
• The customer’s company
Available RemediesAvailable Remedies• Notice of ViolationNotice of Violation• Compliance AgreementCompliance Agreement• Compliance OrderCompliance Order• Cease and Desist OrderCease and Desist Order• SuspensionSuspension• TerminationTermination
• Civil PenaltiesCivil Penalties• Public Notice Public Notice • Criminal ViolationCriminal Violation• Remedies NonexclusiveRemedies 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
The investigation process includes:o Speaking with the person alleged to be in violationo Observing discharge area, storm drain system, surface waterso Taking pictures, videoo 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
Environmental specialists from Environmental Department/Storm Water Services investigate the alleged violation.
Step 3: If Violation Confirmed…
Issue verbal Notice of Violation (NOV)
1st offense (non-willful)Issue written NOV
2nd or continuing offenseIssue written NOV
Issue penalty
Apply other enforcement remedy
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.
Violator must clean up impacted area and submit written response describing corrective actions
1st offense (willful)Issue written NOV
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 ExamplesMaximum 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 sectoro 1 member from environmental organizationo 1 member who is a construction contractoro 1 member from financial, accounting or legal professiono remaining members appointed from a cross section of the community
Appointments by Areao 3 by Charlotte Councilo 3 by County Commissiono 1 by Northern Townso 1 by Southern Townso 1 by other 8 committee members
The Cost of The Cost of Noncompliance Noncompliance
Should Should NOTNOT be less be less than the Cost of than the Cost of
ComplianceCompliance
Environmental Management - System Protection
Ink or Dye
Copper
Window CleanerSoap
Inspectors in Action
If we cannot resolve it, it is time to call If we cannot resolve it, it is time to call the lawyers – please call us or come by the lawyers – please call us or come by
to see us before this happens!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 on-site 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/FortWorthSW.pdf
Michigan Department of Environmental Quality http://www.deq.state.mi.us/documents/deq-ead-tas-powrwash.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 AreasFor 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 Charlotte-Mecklenburg 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 accumulations 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
Environmental
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. HinderliterEnvironmental Chairman PWNA & UAMCCCell: 817-366-3041, Off: 817-529-6601
• Email: [email protected]