The document summarizes regulations and best management practices (BMPs) for mobile power washing businesses. It discusses the Clean Water Act and how it prohibits discharging pollutants into waterways without a permit. It outlines BMPs like containing wash water onsite and discharging only drinking water quality wastewater to sanitary sewers to avoid fines for off-property discharges. The document provides an overview of the NPDES permitting system and its phases that regulate stormwater runoff.

1. BMPs and Regulations for Cosmetic Mobile Power Pressure Washing * San Antonio Water System by Robert M. Hinderliter Environmental Chairman, United Association of Contract Cleaners Website: www. UAmCc.org President, Delco Cleaning Systems of Fort Worth 2513 Warfield Street, Fort Worth, Texas 76106-7554 Phone: 800-433-2113, Fax: 817-625-2059 www.dcs1.com , www.pressurewash.com , www.ikeca.com Note: The products and/or methods shown or depicted in this seminar may be covered by U.S. Letters of Patent . Copyright 2006, Delco Cleaning Systems of Fort Worth, All Rights Reserved (8:15 or 1:15)

3. 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

6. Maximum Fines/day/violation for OFF PROPERTY DISCHARGE : City--$2,000, States--$10,000, EPA--$27,500 Civil EPA--$20,000 & 4 years in jail Criminal Note that the EPA has ‘Civil’ and ‘Criminal’ Penalties.

10. 4. “ Point Source ” means any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill, leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. 5. “ Non-Point Source” : Any source of pollution not associated with a distinct discharge point. 6. AHJ : Authority Having Jurisdiction. 7. POTW : Public Owned Treatment Works (Sewer Plant) 8. MS4 : M unicipal S eparate S torm S ewer S ystem (Storm Sewer Piping. Also includes street gutters and drain ditches along the highway if they empty into waters of the state.)

11. 9. BMP : Best Management Practices means schedules of activities, prohibition of activities, maintenance procedures, and other management practices to prevent or reduce the pollution of the MS4 and waters of the United States. 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. 10. Hazardous Waste may be corrosive, reactive, or toxic. 11. 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. 12. Illicit Discharge: Any discharge to an MS4 that is not composed entirely of storm water with some exceptions.

12. Significant Events Effecting the Mobile Power Wash Industry

13.  Federal Water Pollution Control Act of 1972 o The Federal Water Pollution Control Act of 1972 set the basic structure for regulating discharges of pollutants to waters of the United States and gave the CWA it current form. And established a national goal that all waters of the U.S should be fishable and swimmable. This is the act that first caused Municipalities to do an Environmental Assessment of themselves. Most Regulators refer to the CWA as being passed in 1972. o URL: http://www.epa.gov/region5/water/cwa.htm

16. As long as the water in the child’s wading pool is higher that 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 to filter out debris, sand, & dirt. Does not give a real professional image but it works!

18.  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.

19. Canvas was very heavy when wet.

24. 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, 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 .

25. Typical Power Washing Pollution Typical pollutants in waste washwater that Mobile Power Wash Contractors typically encounter are: Detergents Fats Oils Grease Gasoline Solids Solvents Heavy Metals Herbicides Insecticides Pesticides Total Dissolved Solids Anti-Freeze Emulsified Oil High pH levels caused by Acid Brighteners Fertilizers

27. 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.

30. NPDES for Phase II For Municipalities & Urban Areas (UAs) whether incorporated or unincorporated were due March 10, 2003 For all UA's 50, 000 to 100,000 population Under 50,000 population if notified by the AHJ because of a significant environmental problem. A 5 year plan was required, filings were done 2003, 2004, & 2005, delayed was due to 9th Circuit Court of appeals ruling. “Getting Step with Phase II Workshops” were conducted by the EPA for Municipalities and UAs during 2005 & 2006.

34. Applications for Phase II NPDES permits are due March 10, 2003 from owners of all MS4s located in urban areas (UA’s) with total populations of at least 50,000 and population densities of at least 1,000 persons per square mile. (These MS4s are automatically required to have permits under Phase II). Note: MS4s located in areas with populations of at least 10,000 and population densities of at least 1,000 persons per square mile may be required to obtain a Phase II NPDES permit at the discretion of the EPA or state permitting authority. MS4s located in these less populated areas will have 180 days to file an application from the time they are notified that they are required to obtain a Phase II permit. (Ref: http://www.epa.gov/npdes/regulations/phase2.pdf)

35. These regions may do their NPDES Permits by themselves, combine or hire outside agencies to apply for their NPDES Permits. Notice in the Annual Report for the City of Fort Worth that Co-Permittees are Tarrant County Water District and Texas Department of Transportation, Fort Worth District.

36. 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!

37. As a general rule NPDES Permits are not practical for Mobile Power Wash Contract Cleaners. The average time to obtain this type of permit has been 18 months and they do not apply in Municipalities.

38. 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 significantly less expensive for the cities to require point source remediation than to remediate the pollution at their POTW’s.

39. 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 did grant certain exemptions to this rule and the various cities have also enacted specific exemptions for their area.

41. If anyone offers to sell you an EPA approved product (like detergent) 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.

42. EPA set the standards for cities and states thru their National Pollution Discharge Elimination System Program (NPDES Permits).

43. State’s Responsibilities for Stormwater discharge The EPA can delegate many of the permitting, administrative, and enforcement aspects of the CWA to the states. Then a state becomes a “ Designated State ” (Texas is a designated state). The EPA is still responsible for oversight of state programs. That is because Congress feels that local regulators who know the community can administer the CWA locally better than the EPA can from Washington DC.

44. Cities Responsibilities for Stormwater Discharge 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! This is mainly caused by: jealousy between regulators, different interpretations of the CWA, & different technologies and capabilities of the POTWs.

47. Most of the time Contract Cleaners will be dealing with the local municipality for discharge to their sanitary sewer system connected to their POTW. Usually Kitchen Grease Cleaners will discharge to grease traps on site. Check with the chef to follow this practice. It is not unusual for the Kitchen Exhaust Cleaner to discharge the grease trap under the Risk Management Scenario without asking. Truck Washing and Flat Work Contract Cleaners will be discharging to sand traps when available, like at wash bays.

48. The regulating line of authority is Federal, State, Regional, County, and city. This means that if a city gives you a permit to discharge wash water to storm sewer and you contaminate State waters you are liable to the state! If you get a discharge permit from the state and contaminate federal waters you are liable to the EPA! Note: a discharge permit does not relieve you from liability for contamination clean up.

49. Mobile Power Wash Operators must deal with the City, County, Regional or State Governments who must deal with the EPA for their NPDES permits which specify their Discharge Limits. In most cases this is going to be the local Municipality, but not always. Oregon, South Carolina, & Wisconsin have state programs and California and Florida have regional programs. Kansas City, San Francisco, and Sacramento have metropolitan area programs.

50. Who do you contact at your local municipality for information and permits for Environmental Power Washing Procedures in their city? The problem is that city governments were established before the Clean Water Act was passed. Because there is no standard structure for city governments there are several departments that may be in charge of Power Washing Activities depending on what the government structure is. If the city government has been updated then there will be an Environmental Department. Typically contractors get caught up in the referral system that is a continuous loop with no end. (8:45 or 1:45)

51. In some Phase II Urban Areas the Fire Department is in charge of Fires Suppression, Emergency Medical Treatment, Storm Water Issues, plus more. It is not uncommon for the Fire Department to be a Voluntary Agency.

56. A lot of AHJs state that their interpretation and enforcement of the CWA as being “fact” rather their interpretation and enforcement standard. It is not unusual for this to vary from one regulator to the next within the same department. This has caused some confusion within the Power Wash Contractor Community on exactly what the CWA is and its application to specific situations. Of course if one is receiving a citation at that moment that is the standard! AHJ Variation

58. Effectiveness of the Citation If a citation is given to the Company instead of the contractor it is more effective. It keeps the company from merely changing contract cleaners and puts the company on notice to do things properly.

59. NPDES Permit Violation A violation of their NPDES Permit because of detergents will move waste wash water discharges to the Storm Drain to the top of the list. This has happened in several cities. Regulators will rarely fine Mobile Power Wash Contract Cleaners the maximum but will make certain that the operator does not benefit financially while breaking he law.

60. Environmental Power Washing Items Risk Management Risk Management does not mean zero risk. You will never reach zero risk. What you need to do is reduce your risk as much as possible and still be economically profitable. Almost everyone exceeds the speed limit by a small amount where they do not think that they will receive a traffic ticket. And most of the time they do not get a traffic ticket, but not always! This is risk management. Bankruptcy is now a Risk Management Tool!

61. Risk Takers Usually Government Employees are not risk takers . And usually Entrepreneurs are risk takers . Government Employees survive by not taking risks or being noticed. Do not expect regulators to rule in your favor or interpret the regulations in your favor if it requires a risk on their part. Dilution is the solution to the pollution. The CWA says not to do this, but I have had regulators tell me to do it. Which I did under “Risk Management” scenario.

63. The longer you recycle with the same water the dirtier (more contaminated) it will become. Therefore, you will have to rinse with fresh water and limit your recycle time. Recycling units that will deliver “Drinking Water Quality” discharge water are very expensive and not economically viable for Mobile Wash Contract Cleaners at the present time. Recycle units need to deliver 5 to 20 micron filtered water in order for the water to be recycled through high pressure pumps. This needs to be through a series of filters as a 5 micron filter will immediately stop up with unfiltered power wash wastewater.

65. Note the berm for wash water containment and the sump pump pit in the lower left hand corner of the wash pad.

67. Washwater Control Devices Water Control Devices: 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 Dykes.

68. A Portable Dam sealing off a storm drain, and a sump pump with a window screen filter for discharge to a sand trap.

69. A small hand held surface cleaner with vacuum attachment. Imagine two pie pans separated by about ¼” to form a vacuum chamber with pick up around the edges. The tube at the top of the surface cleaner is the vacuum connection and the trigger gun on the left is from your pressure washer.

70. A close up of the Steel Eagle Hand Held Surface Cleaner in the previous slide.

71. 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.

72. 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. In the City Fort Worth we were able to define Hot Water as any water above 110  F.

73. 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.

74. A window screen has been installed in the drain above to catch the debris, sand, rocks, and dirt. Some municipalities will accept this amount of remediation.

75. Here a window screen and oil absorbent booms have been installed before the drain. Some municipalities will accept this amount of remediation before their drains. The oil absorbent booms will remove the free oils and greases.

76. 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.

77. Note the the oil sheen is only before the oil absorbent boom!

78. Note the the oil sheen is only before the oil absorbent boom!

79. Common cold waterpower booster : zero degree rotating nozzles, and surface concrete cleaners. This zero degree rotating nozzle is used for cleaning vertical grease exhaust shafts (ducts) with either zero or 15 degree nozzles with hot water and chemicals.

80. Zero Degree Rotating Nozzles. Commonly used by Kitchen Exhaust Cleaners with high pressure hot water and chemicals to clean Kitchen Grease Exhaust hoods, ducts, and equipment. Used by Surface Cleaners with high pressure cold water for exterior building and surface cleaning without chemicals for discharging into the storm drain. Precleaning oil and grease spots is usually required.

81. Two examples of surface cleaners with without water recovery capability. Normally these units will handle water up to 5 to 8 GPM, 150 to 200 F, 2000 to 4000 PSI. These units have to be hooked up to a high pressure washer. They are an accessory or tool to increase the production and capability of your pressure washer.

84. Waste materials from dry cleanup such as absorbents, paint chips, etc. may often be disposed of in the trash (dumpster). In general, you must generate less than 220 pounds of a particular type of waste each month to quality to use these “Conditionally Exempt Small Quantity Generator” (ECSQG) programs.

85. 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 products.

86. Phosphate Detergents are fertilizers. In water they cause the algae and moss to grow, which depletes the oxygen supply, causing the fish to die. Neutralize acid cleaners with: baking soda (sodium bicarbonate), soda ash (sodium carbonate), alkaline or caustic detergents & bleach. Use common house hold products if possible if an accidental discharge occurs resulting in observation by Regulating Authorities.

87. Truck Washing For Truck Washing Evaporation and drag-off normally account for 20 to 50% of water loss mainly depending on how warm or hot the ambient temperature is. The washing of Hauling Compartments (Interior of trailers and tankers) should be limited to non-hazardous inert and biodegradable materials.

88. Wastewater Remediation Wash Water Filtration, Remediation Devices: Storm Sewer Drain Screens; Oil Absorbent Pillows, Booms & Pads; Vacuum Systems with Filtration; Pretreatment Units; Limited Recycling Units; Total Recycling Units, flocculation, absorbing media, etc.

89. Mobile Power Wash Recycling Recycling Equipment and Portable Wash Pads are like the ABCs of the alphabet. They are but two tools for Environmental Power Washing. Generally the most expensive tools to use. Other avenues are generally less expensive and more cost effective. Contracts often go to whoever can capture the wash water in the least expensive manner and direct it to Sanitary Sewer. If you recycle long enough the wash water will become hazardous waste. You will 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.

90. Presently most states (including Texas) do not regulate used non-hazardous wash water. Note: some areas of California do regulate used wash water transportation. Also Michigan regulates the transportation of used wastewater for amounts of over 55 gallons. If you are transporting a regulated waste every load will have to be manifested and you will have to obtain the proper permits. If the owner of the waste and the carrier are the same registration is not required. Remember your customer is the owner of the waste.

92. Oil-water separators cannot be used for treating water-soluble chemicals such as anti-freeze and solvents, and detergents that emulsify oil, or the emulsified oil itself. A lot of POTWs discourage the use of recycle units because they concentrate the waste. Because of the heavy oil and grease load from Kitchen Grease Exhaust Cleaning it is generally not competitive to recycle your waste water from this activity. It is generally best to dispose of your waste water into the grease trap on site. Heavy deposits of grease should be appropriately collected (scraping for example) and deposited into a grease container on site if possible. Note: do not deposit grease into the garbage dumpster.

93. Avoid Hazardous Waste A lot of Contractors limit their operations to cosmetic cleaning and avoid: degreasing, two-step chemical cleaning, aluminum brightening, battery cleaning, & the washing of chemical trucks that may produce Hazardous Waste . Treated wood shingles are often treated with a toxic material. Treated shingles 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.

94. Wastewater Discharge Discharge wastewater to Sanitary Sewers as this is the most economical location. If it is not available, then discharge to a Commercial Waste Disposal Facility. This trailer contains a waste water holding tank and Filter Cleaning Tub. The waste water was hauled to disposal site on location away from the lake.

95. A Filter Tub was used to clean the Hood Grease Exhaust Filters in. The waste water was extracted with a Vacuum Sludge Filtering System and discharged to the holding tank above, about 100 feet away.

96. Waste Water was discharged to the restaurant’s septic system by gravity flow under supervision of the chef.

97. Normally you should never dispose wash water to storm drain (note: because so many people confuse the tems “Sanitary Sewer” and “Storm Sewer” it recommended that the tem “Storm Drain” replace “Storm Sewer”.

98. The discharge to the Municipal Sanitary Sewer Systems by Contract Cleaners is insignificant when compared to the total volume that a Municipality processes. When requesting permission to discharge to the Sanitary Sewer always give them an estimate of your volume. Usually “ Hazardous Waste” cannot be discharged to the POTW. A lot of POTWs require contractors that do kitchen grease exhaust cleaning, acid cleaning, two-step chemical cleaning to batch process their wash water and neutralize it before discharging to the sanitary sewer. No off property discharge hazards: 1) soil contamination, ground water contamination, and air contamination. May require soil remediation when property is sold or ground water remediation if contamination becomes known.

99. Sewer Types: Sanitary, Storm, and Combined (sanitary and storm sewer are in the same pipe). Sanitary and combined sewer pipes discharge to the POTW (Public Owned Treatment Works, i.e. sewer plants). Storm drain (sewer) pipes discharge directly to the lakes, rivers, and streams with no remediation. Most outside drains are storm drains and most inside drains are Sanitary Sewer drains. But not always! If you are unsure of whether a drain is a Sanitary Sewer Drain or a Storm Drain ask the Authority in Charge. Sometime this information has been lost over time. Dye or Smoke test may have to be done in order to determine where the drain discharges. In restaurants most floor drains in the kitchen, mop or slop sinks, and disk washing sinks are connected to the grease trap. This is where your waste water should be discharged to. Do not discharge any wastewater into a drain or sewer system if you do not know where it leads and empties into.

100. Discharge wash water to: Sand traps, grease traps, oil/water separators, clarifiers, Utility Sinks, Clean-outs, inside floor drains, commodes, and sinks which are connected to the Sanitary Sewer. They are located at: Truck Wash Bays, Coin-op Car Wash Bays, Automatic Car Washes at Gas Stations, restaurants, and Clean Out Stubs on the outside of buildings where they are connected the Sanitary Sewer. Avoid disposing of your wash water to septic systems or injection wells if possible. These discharge locations are being phased out as of January 1, 2008. You should 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. POTWs are designed to handle sewage related wastes and wastewater, not industrial wastes containing chemicals, metals, oil, etc. (9:15 or 2:15)

101. An example of a Sanitary Sewer Clean Out Port.

102. Another example of a Sanitary Sewer Clean Out Port.

103. An example of a sand trap at a truck wash bay.

104. Storm Drain the empty directly into Lake Tahoe Beautiful Lake Tahoe

105. 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! Washington, DC had a problem with explosive gases building up in the sewers. There would be random explosions blowing off the manhole covers. Sometimes electrical lines and other wiring are in the storm sewers. Caution Do Not Remove Storm Sewer Covers, they are city property.

106. Pretreatment varies for discharging to sanitary sewer from none to extensive and can change at anytime. Most changes in discharge limits are a result of an EPA Fine for violations of an NPDES permit. Caution Do Not Remove Sanitary Sewer Covers, they are city property

108. Wash Water Disposal Options: Wash Water Hauling to proper disposal facility; Direct Discharge Sanitary Sewer; Pretreatment Units then discharge to sanitary sewer; Limited Recycling Units; Total Recycling Units; wash water capture and discharge to sanitary sewer without remediation. Note: Some municipalities prefer that you do not recycle your wash water because recycling concentrates the waste. 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.

109. An example of waste water capture and proper disposal. Not Rocket Science! Think, Imagine, Conceive, Action

110. For Kitchen Exhaust Waste Water Capture starts with draping the hood and funneling the water into a 55 gallon barrel. Note the protection of the ranges and fryers.

111. A hole is cut into the plastic sheeting to allow access to the bottom of the kitchen exhaust hood for high pressure hot water cleaning. In this case 5 gpm at 200  F.

112. Draping a for a roof fan cleaning. Discharge to Sanitary Sewer.

113. Scott Hyde showing the grate in the bottom of a Filter Tub for power washing Grease Exhaust Filters. The grate sets about 4 off the bottom of the Filter Tub.

114. Power Washing grease exhaust filters in the filter tub. 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.

115. Metals like lead and zinc are sometimes found in the outlet water from the tap in higher concentration than the POTW allows! Also Cadmium and Zinc are found in vehicle cleaning compounds in higher concentrations than some POTW allows. No visible oil sheen on the surface of water means 15 mg/l or less of oil.

116. Sludge Collection 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. The lower the level of technology used to collect the sludge the less expensive the collection is . The cheapest place to collect dirt, sand and sludge is right off the wash pad or out a grease duct, fan, or hood.

117. Low level technology clean up.

118. Sludge Disposal Options Sludge disposal options: Put into a Sand Trap; let dry then put into a Dumpster, put the sludge in a 55 gallon drum and have a licensed sand trap service haul the sludge to a proper disposal site, leave with the customer for disposal. The sludge belongs to your customer. Let the customer haul his own sludge to a proper disposal site. You cannot haul it for him unless you are licensed waste hauler. The Waste Disposal site will manifest every load, and if the generator of the waste and the hauler are not the same a registration waste transporter number is required. This is also true of regulated wastewater hauling. You are required to keep the manifest records for 3 years.

119. For Kitchen Exhaust 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.

120. Let the dirt, sand, and sludge dry before disposal to a dumpster. Presently landfills cannot accept liquid waste. In Texas (and most other states) you can put 220 pounds of dry sludge in your dumpster per month. The sludge should be about as dry as damp sand, like on a beach. If you put the sand in a paint filter no water would run out of it. Remember, if the customer is generating other special waste the dirt and sludge will have to be added to this total. The customer should get permission from their refuse company to follow this procedure.

121. Hydrocarbon Disposal Hydrocarbon disposal: for cosmetic cleaning there is none, all of the oil is absorbed by the sludge: waste oil-recycling company (Safety Clean), leave with the customer. Caution: some state classifies used oil as hazardous waste.

122. Used Oil The EPA has classified used oil (hydrocarbons) as non-hazardous if it is destined for recycling, re-fining, reprocessing or burned for energy recovery . Therefore, you should dispose of your used-oil in the aforementioned manner.

123. 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 Also 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.

124. Almost No Hydrocarbons For Mobile Power Washing that is limited to cosmetic cleaning of vehicles and flat work there is very little hydrocarbons accumulated. In fact the dirt and sludge will absorb almost all of the free hydrocarbons.

125. Reportable Quantity In Texas waste oil spills of 9 gallons or more will require reporting to the Texas Commission on Environmental Quality (TCEQ). Therefore, leave the hydrocarbons with your customer or only transport small quantities.

126. Hydrocarbon Disposal Facilities You will need to contact your local waste oil recycling company to see what their requirements are for disposing of your waste oil. Generally there will be an extra charge for oil with dirt, sand, and water in it. Find these companies in your yellow pages under OILS-RE-FINED and OILS-WASTE.

127. What is Oil? The EPA stresses that it defines “oil” to include not only crude oil and petroleum products but also non-petroleum oil, such as vegetable and animal oil. (Ref: EPA Enforcement Alert Volume 3, Number 8. Currently Available at http://www.epa.gov/Compliance/resources/newsletters/civil/enfalert/vol3num8.pdf. You may also sign up for email copies of Enforcement Alert at http://www.epa.gov/Compliance/resources/newsletters/civil/enfalert/).

128. Waste Ownership Customer is owner of the waste from cradle to grave. Only Oregon has rules letting the contract cleaner be responsible for disposal of the waste.

131. House Washing Exemption Note: The EPA exempts residential car washing (as long as it is not a significant contributor of contaminates) 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. This is because it is seldom done. Direct your waste water to landscaping for bioremediation.

132. Landscaping Discharge 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 you discharge to make sure that it does not reach the ground waters through percolation.

133. 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.

135. When washing at a construction site usually a “silt fence”, Straw Bern or other similar structure is required. This “silt fence” should also meet the requirements for solids removal from your wash water at construction sites. (Construction Site Storm Water Discharge Permit - BMPs)

136. An example of a silt fence at a construction site.

137. Straw Berms are replacing Silt Fences at many locations because Silt Fences tend to blow or wash out at the bottom. An example of straw berms.

138. Underground Stormwater Detention/Retention by Cultec, Inc.

139. Underground Stormwater Detention/Retention by Cultec, Inc. www.cultec.com 1-800-4-cultec

140. Compliance and Approval What you need: Letter of approval for Wash Procedures and Letter of Acceptance of your waste from your local regulation authority where you are washing. In most metropolitan areas this will mean a permit from each city you are washing in! Jealousy Between Regulators. In a lot of metropolitan areas the regulators do not respect the competency of each other and there is jealousy between cities. If you try to get approval of your washing procedures by showing city “B” that you already have approval in city “A” expect the requirements to be more restrictive.

141. Drain Plugs It is illegal to install a “Drain Plug” in Municipal Sewer Systems. You could potentially damage the Sewer Systems. Inflatable drain plugs are capable of exerting a lot of force and can damage sewer piping.

142. Presently a lot of Contract Cleaners will get approval for their wash procedures is a major metropolitan city then follow those procedures in other areas without getting the approval of each local regulating authority (Risk Management). 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.

144. Notifying Regulating Authorities Regulating Authorities are not required to investigate every complaint. They are not required to keep the informant confidential. One contract cleaner was particularly upset when he turned in his own customer for refusing to upgrade to Environmental Power Washing and they found out who did it! He lost the account. If regulating authorities are going to be able to write a violation based on your complaint you will have to be willing to testify in court. You can protect yourself by making a anonymous complaint . If enough information is given they will still investigate!

145. Benefits of Compliance Of course the biggest benefit in compliance is doing your part in cleaning up the Environment and avoiding fines. Mobile Power Wash Operators who are willing to invest time, money, and equipment in order to offer Environmental Washing Services and obtain the Certification letters from regulating authorities are receiving a tremendous competitive advantage. It is not unusual for these operators to double or triple their business in a year. Their first advantage generally will be increased enforcement of the Clean Water Act for no off property discharge. Since they are the only one that has 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.

146. 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. Illegal discharging of wash water is not a high priority item for most municipalities unless they have received a violation from the EPA.

147. Greater Kansas City Metropolitan Area issues “Recommended Pollution Prevention Practices for the Mobile Power Wash Industry” with the following statement: “An NPDES permit is required for discharges onto a parking lot, regardless of whether water leaves the property (into a drainage ditch, storm sewer, river, etc.) or not”. This is the only case I know of where the “No Off Property Discharge Rule” comes under regulating authority. The complete document is at: http://www.dcs1.com/del/delpg5/KCbmp97.html

148. Patents Patented Technology: If you use a wash pad with Air Berms or built in berms for recovery of your wash water you will need a License from Environmental Cleaning Systems, Inc. (ECS, Inc) to use this technology. Contact Doug Latimer or Charles Robinson at 519-621-8244 for this license. If you purchase your water recovery equipment from ECS, Inc. it includes the license to use Patented Technology.

149. If you use a flat tarp wrapped around PVC pipe and 2x4 purchased from Delco Cleaning Systems of Fort Worth for your water recovery you will not need a license from ECS, Inc. If you are not sure whether or not your procedures are covered by Patented Technology contact ECS, Inc. for clarification. Also refer to the settlement agreement between ECS, Inc. and Delco Cleaning Systems of Fort Worth covering this technology. The water recovery items purchased from Delco Cleaning Systems of Fort Worth do not violate ECS, Inc. Patents.

153. In the Phase II NPDES Permits there is a “no exposure exemption” for business and industry if they can answer no to the following 11 questions: Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? 1. Using, storing or cleaning industrial machinery or equipment, areas where residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to storm water. 2. Materials or residuals on the ground or in storm water inlets from spills/leaks. 3. Materials or products from past industrial activity.

154. 4. Material handling equipment (except adequately maintained vehicles). 5. Materials for products during loading/unloading or transporting activities. 6. Materials or products stored outdoors (except final products intended for outside use (e.g., new cars) where exposure to storm water does not result in the discharge of pollutants). 7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers. 8. Materials or products handled/stored on roads or railways owned or maintained by the discharger.

155. 9. Waste material (except waste in covered, non-leaking containers (e.g., dumpsters)). 10. Application or disposal of process wastewater (unless otherwise permitted). 11. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under air quality control permit) and evident in the storm water outflow.

156. Notice that Item No. 1, 9, 10, & 11 will require the capture and proper disposal of your wash water, and cleaning up of the wash area so there is no residue from wash operations. This will probably allow your customer to claim a “No Exposure Exclusion". When I posed this question to several regulating officials there was an even split on whether a company could claim this “no exposure exemption” or not. If were a contract cleaner I would shop for the answer I needed! (If you do like Mommy answer go to Daddy!)

157. Phase II, “Illicit Discharge Detection and Elimination Minimum Control Measures” is composed of 5 sections: 1. A storm Sewer Map 2. An ordinance prohibition on non-storm water discharge to the MS4 (Municipal Separate Storm Sewer System), 3. A plan to detect and address non-storm water discharges, including illegal dumping, into the MS4

160. 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 that one type of device to capture, control, and clean wash water with. Because washing with a Recycling Systems on a Portable Vinyl Wash Pad is the most expensive way to wash an item this needs to be the option of last resort.

161. The Big Problem Cities or Urban Areas who don't know the pollutants in the discharges or the volumes might be more likely to assume the worst. And since they are on the hook if something goes wrong at their wastewater treatment plant, they may react over-cautiously on allowing discharge to a sanitary sewer. (Notice the effect of the economic revenue stream )

162. Cost of Compliance There is going to be a cost associated with the control of discharged Power Washing Waste Water. Enacting Regulations prohibition the discharge of Power Washing Waste Water to the Storm Drains with enforcement by complaint basis only will have very little effect on stopping this waste water from entering the storm drain system (MS4).

163. Compliance Enforcement Effective enforcement requires a consistent 24/7 enforcement action. Some municipalities have done enforcement programs for night and weekends for a 30 day period. This temporarily solves the program but with the large number of part timers entering the business the effect soon wears off. Within a short period of time the industry is back to unregulated power washing. This creates a yo-yo effect in enforcement and compliance.

165. As business and government come to grips with what to do with wastewater it is obvious that it has to go somewhere. The most obvious place is for it to go to the POTW. POTWs serve the needs of the community by treating discharges to the sanitary sewer system. In Texas there are no combined sewer systems. Sanitary Sewers go to a POTW for treatment, Storm Sewers (MS4s) discharge straight into an adjacent stream or river. Communities are responsible for their Stormwater Discharges through their TPDES Permits. Programs are required to monitor for water quality and to eliminating illegal discharges. If communities do not provide an economical place for wastewater discharge then this activity will be done nights and weekends to avoid detection.

166. These illegal discharges will end up in the storm sewer. These discharges are typically an insignificant percentage of the contribution of the total contaminates to sanitary sewer and a significant contributor of pollutants to the storm drains. Sooner or later communities will open up their POTWs to these wastewater discharges. The problem is that they have not been doing this in the past, so it is something new!

167. Minimizing the Cost of Compliance The city that has enacted the best overall regulation with a highest level of voluntary compliance is Fort Worth, Texas. This regulation was the result of a “Mobile Power Washing Environmental Protection and Compliance Conference” held during a Public Comment Period. The meeting was attended by about 40 Federal EPA, State, Regional, and Municipal Environmental Regulators and 100 Contract Cleaner and Industry Representatives. Detergents detected in the storm drains has decreased from over 50% of the storm drains to as low as 5% since the ordinance was enacted January 2, 1996. The Fort Worth Regulations are now up on the EPA’s Website as an example.

169. 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. Adopting the above regulations will produce the highest level of voluntary compliance with the minimum cost . This conclusion is based upon the positive experience of these regulations over time.

170. 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.

171. 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. 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)

173. 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.

174. 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."

175. Links to the Fort Worth Code: City of Fort Worth: http://www.fortworthgov.org/DEM/powerwash.htm EPA: 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 Delco Cleaning Systems Summary (note: see first) http://www.dcs1.com/del/delpg5/fterpt.html

176. BASMAA Pollution Prevention Voucher – On file for 3 years

177. Robert M. Hinderliter (PWNA Environmental Chairman) meets with Robert White (Manager Sacramento County B usiness E nvironmental R esource C enter) October 22, 2002 during the Comment Period for the BMPs for Mobile Power Washing. BERC was very interested in receiving comments from a National Trade Organization on their proposed BMPs. PWNA was initially told that the comment period had ended but that they would be glad to receive comments any way for future revisions. PWNA immediately submitted comments. 12 of 14 items were accepted from PWNA. The final BMPs were released on November 8, 2002.