ENVIRONMENTAL MOBILE PRESSURE POWER WASHING

(Reality of Enforcement, December 18,1995)
Last update: March 15, 1999

Written By

Robert M. Hinderliter

Edited by

Don E. Kerzee, Larry Hinckley, Greg Foster, & Michael Hinderliter

of

RAHSCO Cleaning Systems

2513 Warfield Avenue, Fort Worth, Texas 76106-7554

Canada/U.S. Wats: 800-433-2113

Fax: 817-625-2059

REPORT NO. 507

Copyright , RAHSCO Cleaning Systems All rights reserved

FORWARD

Environmental Power Washing

Environmental Power Washing is the proper environmental disposal of your used wash water. Exactly what this is will be defined on a local basis, usually by the Local Municipality. Mobile Power Wash Recycling is but one of the many techniques used to meet this criteria.

Copyright , RAHSCO Cleaning Systems of Fort Worth. All rights reserved.

 

TABLE OF CONTENTS

  1. The EPA and Environmental Compliance
  2. Storm Water Permits
  3. No off property discharge
  4. Sewer Type
  5. Wash Areas
  1. Disposal of Wash Water--Sanitary Sewer
  2. Disposal of Wash Water to Storm Sewer
  3. Recycle Wash Techniques

                                                                               I.            30% to 50% Loss due to Evaporation and Drag Off

                                                                            II.            Fresh Water Rinse

  1. Sludge Disposal Options
  2. Hydrocarbon Disposal (used oil)
  3. Hazardous Classification
  4. Waste Ownership
  5. Wash Water Management
  6. What Your EPW Customers will require
  7. Risk Management
  8. Opportunity speaks, are you listening?

ACRONYMS and DEFINITIONS

BOD--Biochemical Oxygen Demand
BMP--Best Management Practices
COD--Chemical Oxygen Demand
EPA--Environmental Protection Agency
FOG--Fats, oils, and greases
Heavy Metals: Arsenic, Barium, Boron, Cadmium, Chromium, Copper, Lead, Manganese, Mercury, Nickel, Selenium, Silver, Zinc
mg/l--Milligrams per liter
MS4--Municipal Separate Storm Sewer System (Storm Sewer, i.e. Storm Drain)
NPDES--National Pollution Discharge Elimination System
Portable Vinyl Wash Pit--Is a Flat Tarp Portable Vinyl Wash Pit.
POTW--Public Owned Treatment Works (Sanitary Sewer Plant)
Sand trap--may be: Coalescer, Clarifier, Oil/Water Separator, Grease Trap, or Grit Trap
Storm Drain--Replaces the Term Storm Sewer because of confusion by the public
TCLP--Toxicity Characteristic Leaching Procedure extract
TNRCC--Texas Natural Resource Conservation Commission
TPH--Total Petroleum Hydrocarbons
TSS--Total Suspended Solids


 

 

  1. THE EPA AND ENVIRONMENTAL COMPLIANCE

Off property discharge of Vehicle Wash Water is a violation of the Clean Water Act. Daily fines can be: Cities--$2,000.00 per day, States--$10,000.00 per day, and the EPA--$25,000.00 per day. The American Trucking Association had their first ever National Conference on Environmental Vehicle Washing April 6 & 7, 1995 in Fort Lauderdale, Florida. RAHSCO Cleaning Systems was a sponsor of that seminar.

 

  1. STORM WATER PERMITS

The portion of the Clean Water Act that is effecting Mobile Power Washing the most is the National Pollution Discharge Elimination Systems (NPDES) Permits required by the EPA for Storm Water runoff. NPDES Permits are basically storm water management plans. The NPDES Permits effecting Mobile Power Washing are the ones required for States, Cities, and Fleet Owners. These permits require the cleaning up of Rain Water and Snow Water runoff into our lakes and streams. This includes the elimination of pollution from washing operations entering our lakes and streams carried by Storm Water runoff.

The American Trucking Association had their first ever National Conference on Environmental Vehicle Washing April 6, & 7, 1995 in Fort Lauderdale, Florida. RAHSCO Cleaning of Fort Worth was a sponsor of that seminar. There were over 180 people in attendance, and some of the companies represented were: Adams Motor Express, Allwaste Container Services, Anderson Concrete Corporation, Alterman Transport Lines, Blue Shores Distributing, Buffalo Fuel Corporation, Catwba Rental Company, City of Delray Beach, Commercial Carrier Corporation, Contractors Chemical Corporation, Dana Container, Deans Foods Company, DSI Transport, Federal Express, Florida Power and Light, Florida Transport Company, Stoops Freightliner, Gator Leasing, General Parcel Service, Gold Kist Incorporated, R. O. Harrell Incorporated, Hogan Motor Leasing, Iowa 80 Group, Keen Companies, Kenan Transport Company, Landstar Poole Incorporated, R. L. Leek Industries, Liquid Carbonic Industries, Martin Brower, Matlack Incorporated, Mitchell Transport, National Auto/Truck Stops, National Automobile Dealers Association, Oakwood Service LTD, Paccar Leasing Corporation, Pals Express, Penske Truck Leasing, Pepsi Cola, Pitt Ohio Express, ProSource Distribution, Roadway Package Systems, Rollins Truck Leasing, Ruan Leasing Corporation, Ryder Truck Rental, Shelton Trucking Service, Southeastern Freight Lines, Super Transport Incorporated, SuperValu, Texas Instruments, Texo Corporation, Transport International Pool, Union Pacific Properties, United Parcel Service, UPS Truck Leasing, US Army Reserve Command, US Postal Service, Victory Express, Watkins Motor Lines, and Yellow Freight Systems. All of these companies are in the process of implementing Environmental Correct Vehicle Washing Procedures. And companies that are utilizing the services of Contract Cleaners are going to require that Environmental Correct Vehicle Washing Procedures be used!

What happened in Fort Worth, Texas is typical across the Nation. In 1993 the Department of Environmental Management tested over 560 storm water sites within the city of Fort Worth. Detergent was discovered in over 50% of these sites making detergent the most encountered pollutant in the City. It was determined that cosmetic cleaning was a significant source of these detergents. The EPA is giving the City of Fort Worth five (5) years starting in 1996 to show a decrease in the pollutants at the 560 sites. If the city does not clean up its storm water the EPA may require a treatment plant to be constructed at the cost of several hundred million dollars similar to the Sewer Treatment Plant to treat all of the storm water. Therefore, starting in January 2, 1996 all of Mobile Power Wash Operators will have to be license in the City of Fort Worth. This license will include a permit to discharge to the sanitary Sewer for cosmetic cleaning of un-concentrated wash water.


 

 

  1. NO OFF PROPERTY DISCHARGE

 

Uncontrolled vehicle washing is presently being permitted in Arizona and Iowa. This is for cosmetic washing with biodegradable detergents. Contact Representative for Arizona is Bill Engstrom at 602-207-4696 and for Iowa is Steve Williams at 515-281-8884. While these two states may have decided not to regulate Mobile Power Washing at this time the individual Cities may in fact do so!


 

 

  1. SEWER TYPE

 

The Storm Sewer is where the rain water goes in to gutters along the streets and roads. This water is generally discharged directly to lakes and streams without treatment. Because this water is not remediated before discharge into the environment you should not discharge your wash water to a storm sewer.

 


 

 

  1. WASH AREA

 

 


 

 

  1. DISPOSAL OF WASH WATER TO SANITARY SEWER

 

 


 

 

  1. DISPOSAL OF WASH WATER TO STORM SEWER

 


 

 

  1. RECYCLE WASH TECHNIQUES

Recycle Units clean the water only enough so that the water is suitable for washing but not rinsing. Recycle Units that clean the water to rinse water quality are too expensive for contract cleaners. Therefore, rinsing will have to be done with fresh water. Normally recycle units do not remove detergents, total dissolved solids, or heavy metals. This means that your detergent usage will decrease, but it also means that if you recycle the wash water long enough it will test hazardous and have to be disposed of at a Hazardous Waste Facility and you may have to obtain a Hazardous Waste Generator Permit. The trick is to recycle the wash water only long enough that it is still within the discharge limits of the sanitary sewer and before it tests hazardous. A popular technique of many Environmental Power Wash Contractors is to limit their business to cosmetic cleaning of nonhazardous items and not to do heavy degreasing, acid or two step washing, heavy brushing, or aluminum brightening as these activities cause problems with Heavy Metals, and Hydrocarbons. For cosmetic cleaning of nonhazardous items you should be able to recycle for one or two days and still stay under sanitary sewer discharge limits with filtration and absorption technologies. Examples are: Vacuum Sludge Filtering Systems, and the Recycle 16.

 


 

 

  1. SLUDGE DISPOSAL

 

Note: You can find Sand Trap, Grit Trap and Grease Trap Services under GREASE TRAP and MUD TRAP SERVICE in the yellow pages.


 

 

  1. HYDROCARBONS DISPOSAL (used oil)

 

 

  1. HAZARDOUS CLASSIFICATION

 

 

  1. WASTE OWNERSHIP

Ownership of any Hazardous Waste and Special Waste that is regulated by state or local agency is the generator of that waste. Presently this ownership cannot be transferred under any circumstances. Therefore, your customer owns the waste from your washing operations and he is responsible for the waste forever. Your customer is still responsible for his waste even after a licensed waste hauler picks it up. The waste generator is responsible from cradle to grave under present law. This means that if the licensed hauler illegally disposes of his waste he maybe liable for clean up! Presently the only exception to this is in the state of Oregon where ownership can be designated as either the Contract Cleaner or the Customer.


 

 

  1. WASH WATER PROCESSING EQUIPMENT

There are five distinct categories of Wash Water handling equipment, they are:

 


 

 

14.  WHAT YOUR ENVIRONMENTAL POWER WASH CUSTOMER WILL REQUIRE

 


 

 

15. RISK MANAGEMENT

 

As you travel the nations Interstate Highways its obvious that the enforced speed limit is not 55 MPH. The most enforced speed limit is 70 MPH. Rarely is a traffic ticket given for under 70 MPH. But if you requested authorization to drive 68 MPH you cannot get it. So we have a written speed limit and an enforced speed limit. If you drive 68 MPH your risk of receiving a ticket is minimal and a risk that most people are willing to take. Why is this important to the Environmentally Correct Mobile Power Wash Operator? Because a lot of what you will be doing will be risk management. The exact Mobile Power Wash Procedures that satisfy the Clean Water Act are not clearly defined and the procedures fall between the cracks of existing regulations. You can find as many interpretations of the regulations as you can find environmental regulators.

o    What happens if you are cited for improper washing procedures and your competitor is not? Normally this puts you at a competitive disadvantage with customers who are not environmentally conscious. These customers will probably go with the lowest bid. Environmentally correct washing is more expensive and puts you at a competitive disadvantage. Many Mobile Power Wash Contractors have been faced with this problem. Now they are in a position of not being able to provide for their families because of an uneven playing field. This is not an unusual situation and it is happening over and over again as Environmentally Correct Washing Procedures are being implemented. Again you are effecting the revenue stream. Because of this economic pressure it not unusual for competitors to turn each other in for improper washing procedures. Taking photographs, videotaping, and calling regulating authorities about improper washing procedures by a competitor or customer is not unusual. This will probably continue as long as there is such a wide variation in interpretation and implementation of Environmental Washing Procedures to satisfy the Clean Water Act.
 

16. OPPORTUNITY SPEAKS, ARE YOU LISTENING?

This State of Confusion spells opportunity for many contractors. Never again will it be so easy to influence how the Clean Water Act will be implemented in your area. Those contractors who are the first ones in their service areas to offer and promote Environmental Power Washing are reaping the rewards of their efforts. Environmental Power Washing is the growth area for Power Washing Today. Just one example is the Post Office. In Fall of 1994 they abruptly stopped all washing on their property that was not Environmentally Correct. More and more customers will take this position as they become aware that there is a viable solution to their cleaning problems. Another example is the American Trucking Association which will hold their first national conference on vehicle washing in April of 1995 in Fort Lauderdale, Florida. Opportunity speaks, are you going to listen. Now is the only opportunity you will ever have to make such a big impact on the implementation of Environmental Washing Procedures with so little effort. Timing is everything and the time is now!!!!


 

 

1997 Mobile Pressure Power Washing Environmental Update

By: Robert M. Hinderliter
RAHSCO Cleaning Systems
October 10, 1997

Environmental Power Washing is not just Mobile Recycle Pressure Washing on a Portable Vinyl Wash Pit. These are but two elements of Environmental Power Washing just like "a", "b", "c" are letters of the alphabet. Simply stated Environmental Power Washing is Pressure Washing with "No Off Property Discharge" and discharging your wash water to the Sanitary Sewer. This definition will fit most pressure washing operations that are being done within Environmental Guidelines. It should be noted that "No off property discharge" means above and below ground and discharge to Sanitary Sewer means any place that is properly approved to receive your wash water. The most common discharge location is Municipal Sanitary Sewer Systems (or POTW: Public Owned Treatment Works). The preferred entry point is a Sand Trap, or a Grease Trap. Many municipalities are also allowing other points of entry such as slop sinks, mop sinks, sanitary sewer clean outs, commodes, inside floor drains, etc.

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 tool box 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 Contractor to have more than 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.

Recycle Systems do not remove the Total Dissolved Solids, Heavy Metals, Detergents, Herbicides, Insecticides, or Pesticides. Hence the longer you wash with Recycled Water the harder it is to get something clean and you have to rinse with fresh water. Therefore washing with Recycled Water needs to be the option of last resort. The same is true for washing on a portable vinyl wash pit. Articles have to be moved to the wash pit. Often times washing items in place then capturing the wash water is a less expensive option.

Many municipalities will now accept wash water with minimal pretreatment. This is because the impact of the wash water from Contract Cleaners on the on the POTW (Sewer Treatment Plant) is insignificant. It should be noted that each municipality has the authority to determine what is acceptable within its city limits. The problem is if you are in a Metroplex area where there are many municipalities each one will probably have a difference set of Environmental Pressure Washing Guidelines. What causes this is mostly politics and jealousies among the cities.

Common water control devices are (Tools for your tool box): Recycling Systems; Pretreatment or sewer discharge Systems; Limited Recycling Systems; Wash Pits (portable vinyl wash pads), Vacuum Sludge Filtering Systems; Wet-Dry Vacuums, Sump Pumps; Drain Covers; Portable Dams; Vacu-booms; Oil Absorbent Pads, booms, pillows, and tubes; plastic sheeting; Filter Tubs; buckets; pans; and squeegees. You will be designing all sorts of devices to control the water flow. Sometime that will just be using the terrain and natural drainage and catching the water at a low spot to accomplish "no off property discharge". Sometimes this can be as simple as using a wet/dry vacuum and vacuuming up the water before off property discharge. Do not forget about evaporation. A lot of contractors have used evaporation effectively enough that they can wash for several hours and only have to recover less than 55 gallons of wash water. This has been done mostly by letting wash water make long runs across concrete then capturing the water just before it leaves the property. After the washing is finished they clean up the concrete. "No off property discharge" has been achieved and the wash water has been discharged to sanitary sewer. Environmental guidelines have been met.

Note that in most locations if the wash water does not exit the property it does not enter the jurisdiction of the Regulating Authorities.

For more information see "Environmental Mobile Power Washing, Reality of Enforcement" on the internet at: http://www.dcs1.com/del/delpg5/rept507.html  and "Fort Worth Environmental Regulations for Mobile Pressure Power Wash Cosmetic Cleaning" on the internet at: http://www.dcs1.com/del/delpg5/fterpt.html  Copies can also be ordered from RAHSCO Cleaning Systems at 800-433-2113.

 

 

Return to Environmental Power Washing Report Index

Fort Worth Environmental Regulations for Mobile Power Wash Cosmetic Cleaning

Return to RAHSCO Cleaning Systems Index at http://www.dcs1.com

Robert M Hinderliter, RAHSCO Cleaning Systems
2513 Warfield St., Fort Worth, Texas 76106-7554
email: rahsco@dcs1.com_ ; URL: http://www.dcs1.com
Phone: 800-433-2113; Fax: 817-625-2059.
 

Copyright 1997-1999, RAHSCO Cleaning Systems. All rights reserved.