UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6
1445 ROSS AVENUE
DALLAS, TX 75202-2733

February 16, 1996

Re: Discharges of Vehicle Wash Water

Dear

Discharge of vehicle wash waters to a Water of the United States, even if via a separate storm sewer system, does legally required a National Pollutant Discharge Elimination System (NPDES) permit. In addition, section 402(p) of the Clean Water Act requires NPDES permits for the discharge of storm water associated with industrial activity. The definition of “discharge of storm water associated with industrial activity” at 40 CFR 122.26 (b) (14) includes Post Offices, certain motor freight, most manufacturing facilities, etc.

The facility operator is typically required to address storm water runoff from vehicle maintenance (including washing) areas at these facilities. Please note that there is a difference between the actual wash water which has required a waste water NPDES permit since 1972, and the storm water runoff from the areas where the vehicle washing occurs which has required a storm water NPDES permit since October 1992.

It is our understanding you are primarily concerned with the vehicle wash water generated during on-site car and truck washing by contract mobile pressure washers. There are alternatives to obtaining a NPDES permit, and several of these options offer opportunities for pollution prevention, rather reaction.

Since an NPDES permit is only required for a point source discharge of pollutants, several scenarios where a permit would not be required include:

• If a “dry” wash method is used, no waste water is generated, so there is no discharge that would require a permit.
• If wash water is collected and recycled for reuse, there would be no point source discharge at the wash site and therefore no need for a permit. The wash waters could be collected in many ways, including commercially-available portable devices similar to a child’s inflatable swimming pool that a vehicle is driven onto and then washed; blocking the storm drains with specialized plugs or simple plastic and sandbag-type devices; use of a wash rack with drains to a storage vault; etc. We understand this type of process is commercially available within the power washer industry.
• If wash water is collected and disposed of into a sanitary sewer (e.g. wash rack plumbed to sanitary or water collected and dumped into sanitary sewer system on site), there would be no point source discharge at the wash site and therefore no need for a permit.
• If wash water is collected and taken off site to a public or private waste water treatment plant, or discharged off site to the sanitary sewer system, no permit would be needed. Note that the public or private waste water treatment plant would need to have it’s own NPDES discharge permit.
• If wash water is collected and applied to the land (e.g. for irrigation, etc.) or otherwise allowed to evaporate (e.g. an evaporation pond) without ever being discharged, there would be no need for a permit. Note that the land application of the wash waters could, in certain circumstances, trigger the need for a storm water discharge permit for the application site.

In most cases, it is the responsibility of the operator of the facility where the discharge occurs to obtain a permit for discharges from that site.

A waste water permit would only be required if:

• Wash water is allowed to run off the property and into a conveyance, including a storm water drain, leading to a Water of the United States.
• Wash water is collected and transported off site, where it is then discharged.

The party taking waste water off-site, and not the facility operator, would be responsible for proper disposal of the wash waters removed from the site. Disposal into a sanitary sewer would require permission from the local city or waste water authority and compliance with any applicable industrial pretreatment requirements. Illegal dumping of wastewater could result in fines from the local municipality, the State, and/or the Environmental Protection Agency.

Any facility with “storm water associated with industrial activity” would still need to obtain a storm water permit for the areas where any vehicle maintenance, including washing, fueling, or mechanical repair, occurs. However, this would be the case regardless of the vehicle wash method used, unless the all storm water from these areas was also captured and prevented from discharging.

Those with stationary car and truck washes have had to have pollution control equipment for compliance with NPDES permits or a municipality’s pretreatment program for years. It is only fair that mobile systems not receive a competitive advantage over the stationary car and truck washes by avoiding environmental laws.

We hope this information aids you in understanding the various means a vehicle washing contractor may use to comply with the Clean Water Act. EPA certainly does not intend to stand in the way of innovation in the private sector and actively supports efforts to incorporate pollution prevention in compliance efforts.

If you have any further questions, please feel free to contact me at 214-665-7523, or Brian Burgess at 214-665-7534.

Sincerely,

Brent Larsen

NPDES Permits Branch (6WQ-PM)

Note: The following information if from the EPA to the USPS. USPS is the largest fleet operator in the world. We believe it came from Region 6. It is included here for reference information because of its significance.

ADDITIONAL INFORMATION FROM THE USPS

Provided here for reference purposes only

Discharge of vehicle wash waters to a Water of the United States, even if via a separate storm sewer system, does legally required a National Pollutant Discharge Elimination System (NPDES) permit. In 1987, Congress added section 402(p) to the Clean Water Act Included in Phase I of the new NPDES storm water program were discharges associated with industrial activity. The definition of "discharge of storm water associated with industrial activity" at 40 CFR 122.26 (b)(14) includes storm water runoff from vehicle maintenance (including) washing) areas at Post Offices (category viii). Note that there is a difference between the actual wash water which has required a waste water NPDES permit since 1972, and the storm water runoff from the areas where the vehicle washing occurs which has required a storm water NPDES permit since October 1992.

It is our understanding the U.S. Postal Service is primarily concerned with the vehicle wash water generated during on-site car and truck washing by contract mobile pressure washers. There are alternatives to obtaining a NPDES permit, and several of there options offer opportunities for pollution prevention, rather reaction

Since a NPDES permit is only required for a point source discharge of pollutants, several scenarios where a permit would not be required include:

1. A. If a ‘dry" wash method is used, no waste water is generated, so there is no discharge that would require a permit.
   
   
2. If wash water is collected and recycled for reuse, there would be no point source discharge at the Post Office and therefore no need for a permit. The wash waters could be collected in many ways, including commercially-available portable devices similar to a child’s inflatable swimming pool that a vehicle is driven onto and then washed; blocking the storm drains with specialized plugs or plastic and sandbag-type devices; use of a wash rack with drains to a storage vault; etc. We understand this type of process is commercially available within the power washer industry.
   
   
3. If wash water is collected and disposed of into a sanitary sewer, there would be no point source discharge at the Post Office and therefore no need for a permit.
   
   
4. If wash water is collected and taken offsite to a public or private waste water treatment plant, or discharged offsite to the sanitary sewer system, no permit would be needed. Note that the public or private waste water treatment plant would need to have it’s own NPDES discharge permit.
   
   
5. If wash water is collected and applied to the land (e.g. for irrigation, etc.) or otherwise allowed to evaporate (e.g. an evaporation pond) without ever being discharged, there would be no need for a permit. Note that the land application of the wash waters could, in certain circumstances, trigger the need for a storm water discharge permit for the application site.
   
   A waste water permit would only be required if:
   
   
6. Wash water is allowed to run off the property and into a conveyance, including a storm water drain, leading to a Water of the United States.
   
   
7. Wash water is collected and transported offsite, where it is then discharged. In this case it is the responsibility of the person transporting or accepting the wash water to be the responsible party.
   
   

The party taking waste water off-site, and not the Post Office, would be responsible for proper disposal of the wash waters removed from the site. Disposal into a sanitary sewer would require permission from the local city or waste water authority and compliance with any applicable industrial pretreatment requirements. Illegal dumping of wastewater could result in fines from the local municipality, the State, and/or the Environmental Protection Agency.

The Post Office would still need to obtain a storm water permit for the areas where any vehicle maintenance, including washing, fueling, or mechanical repair, occurs. However, this would be the case regardless of the vehicle wash method used, unless the all storm water from these areas was also captured and prevented from discharging

Those with stationary car and truck washes have had to have pollution control equipment for compliance with NPDES permits or a municipality’s pretreatment program for years. It is only fair that mobile systems not receive a competitive advantage over the stationary car and truck washes.

It appears the U. S. Postal Service has not fully explored all the means a vehicle washing contractor may use to comply with the Clean Water Act. EPA certainly does not intend to stand in the way of innovation in the private sector and actively supports efforts to incorporate pollution prevention in compliance efforts.

Environmental Power Washing Reports and Ordinances

Delco Cleaning Systems of Fort Worth
2513 Warfield Street, Fort Worth, Texas 76106-7554
Phone: 800-433-2113; Fax: 817-625-2059
URL: http://www.dcs1.com/del ; email: delco@dcs1.com

Last updated: November 18, 1997 by Robert M Hinderliter

Copyright 1997 Delco Cleaning Systems of Fort Worth. All rights reserved.