Update: May 8, 2006
The California Storm Water Toolbox includes the following tools for residents, community and civic groups, educators, municipalities and public agencies:
All elements of the California Storm Water Toolbox are available for download, free of charge at www.erasethewaste.com.
Storm Water Program Litigation, EPA Guidance on the 9th Circuit Court Decision for MS4's at: http://yosemite.epa.gov/R10/WATER.NSF/0/8acf5918641f087b88256ce00074ca17?OpenDocument
Implementing the Partial Remand of the Stormwater Phase II Regulations Regarding Notices of Intent (NOI) & NPDES General Permitting for Phase II MS4s at http://www.epa.gov/npdes/pubs/hanlonphase2apr14signed.pdf
State Environmental Agencies Links from the EPA at http://www.epa.gov/epahome/state.htm
Phase II Workshops for Regulators
Getting Stepwith Phase II Workshops 2005 Schedule at http://www.watershedtraining.net/p2wrkshp.cfm
Getting In
Step with Phase II Workshops for Regulators at
http://cfpub2.epa.gov/npdes/outreach.cfm?program_id=0&otype=1
Fort
Worth, Texas - May 3-4, 2006, Albany, New York - May 31 - June 2, 2006,
Phoenix, Arizona - August 14-15, 2006, Lexington, Kentucky - September 21-22,
2006
Excellent Resources for Phase II NPDES Permints and MS4 Operators
Pollution Prevention Practices for Surface Cleaning Created by NAPA-SOLAND-SONOMA Stormwater Agencies (NSSSA) at http://city.ci.st-helena.ca.us/images/aad/Docs/SurfaceCleaner%20Guide12.04.pdf
Stormwater Best Management Practice (BMP) Handbooks from CASQA (California Stormwater Quality Association) at http://www.cabmphandbooks.com/
Model Urban Runoff Program (MURP) from the The Cities of Monterey, Carmel-by-the-Sea, Del Rey Oaks, Sand City, Seaside, Marina, Pacific Grove, the County of Monterey, and the Pebble Beach Company at http://swrcb2.swrcb.ca.gov/stormwtr/murp.html and http://www.monterey.org/publicworks/water.html
Guidance for Cosmetic Mobile Power Wash Contract Cleaners
Environmental Cleanup: Why and How to Get Involved & Do It Now at http://www.dcs1.com/regs/cleanup.html
Cosmetic Mobile Power Washing Waste Water is:
If the regulations are not Reasonable, Rational, and Logical then the industry will go underground and discharge waste water to the MS4s on nights and weekends when enforcement is at its lowest.
If the regulations (BMPs - Best Management Practices) are Reasonable, Rational, and Logical with access to the Sanitary Sewer at a reasonable (Fort Worth is $25.00 per company plus $25.00 per rig per year) cost than there will be a high level of voluntary compliance. This has been proven with over 9.5 years experience by the city of Fort Worth, Texas.
On Line Training from BASMAA
Bay Area Stormwater Management Agencies Association (BASMAA) of the San Francisco Bay Area has put their Cosmetic Mobile Power Washing Training (Pollution Prevention Training for Surface Cleaners) online at http://www.basmaa.org. Click on "View" our 30 minute presentation on the right hand side of the page and follow the login prompts.
Regulations for Cosmetic Mobile Power Washing
Robert M. Hinderliter's Presentation BMP's and Regulations for Cosmetic Mobile Power Pressure Washing - Reality of Enforcement presented at the 6th Annual EPA Region 6 MS4 Storm Water Conference in New Orleans on July 7, 2004 and at StormCon "The North American Surface Water Quality Conference & Exposition for Environmental Regulators and Professionals on July 29, 2004 was called feisty by Environmental Regulators. However, no one disagreed with Robert's presentation, it was just that the some items presented generally remained unspoken. The presentation was update and repeated at StormCon 2005 in Orlando, FL July 20, 2005.
Presentation was in two parts.
The following information is provided as service to Phase II areas as a resource guide for developing regulations for their MS4 pertaining to Power Washing. Fort Worth, Texas and Sacramento, California are good examples to follow. If you want an ordinance then Fort Worth, Texas is a very good example. It was passed by City Council and became effective January 2, 1996. If you want a "BMP" than Sacramento is a very good example. Both regulations were developed with extensive Public Comment Periods with input from business and industry.
If possible Power Washers of North America (a national association of power wash contract cleaners,www.pwna.org) would like for you to consider adopting the BASMAA "Pollution Prevention Voucher" and requiring it to be on file for 3 years. This should greatly stabilize enforcement and compliance. This should be minimum cost for the Contract Cleaner, his customer, and the municipality.
Mobile Pressure Washer Survey Template
Mobile Pressue Washer Fact Sheet
Mobile Pressure Washer Information Form
  Robert M. Hinderliter (PWNA Environmental Chairman) meets with Robert White (Manager Sacramento County Business Environmental Resource Center) October 22, 2002 during the Comment Period for the BMPs for Mobile Power Washing. |
| For additional information
contact Robert M. Hinderliter (PWNA Environmental Chairman) at Phone: 800-433-2113, Fax: 817-625-2059, Email: robert@dcs1.com |
| For additional information for
Environmental Regulators only contact M. Robert White, Manager, BERC, Sacramento County Phone: 916-364-4110, Fax: 916-364-4115, Email: rwhite@sacberc.org |
Most municipalities enforce environmental wastewater discharge regulations based on complaints only. Regulators are limited on time and budget. They spend their time on the items that have the greatest impact on their cities. Normally wash water discharges to the storm sewers are low on the priority list. 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.
Compliance is mostly based on a voluntary effort with low priority of enforcement becuase of time and budget restrictions. The greatest amount of compliance with the least amount of effort can be obtained by adopting BASMAA's Pollution Prevention Voucher and requiring it to be on file for 3 years by both the contract cleaner and his customer. This time period has been adopted by the Michigan Department of Environmental Quality. Also the MDEQ allows discharging to ground for Cosmetic Cleaning up to 1,000 gallons per month per acre. For more information go to http://www.deq.state.mi.us/documents/deq-ead-tas-powrwash.pdf
Power Washers of North America (http://www.pwna.org) recommends adopting the BASMAA "Pollution Prevention Voucher" and requiring it to be on file for 3 years.
Fort Worth Environmental
Regulations for Mobile Pressure Power Wash Cosmetic Cleaning
and
Mobile Commercial Cosmetic
Cleaning
For additional information for
Environmental Regulators only contact
Brian L. Camp, Jr.,
Environmental Program Manager
Environmental Management Department, Water
Quailty
City of Fort Worth, Texas
Phone: 817-871-5458, Fax: 817-871-5464,
Email: CampB@ci.fort-worth.tx.us
Oregon BMPs for Washing Activities
Wastewater Discharge Permit (General Permit)
Application to be included under the general permit
Additional Environmental
Information from Delco Cleaning Systems of Fort
Worth
and
Storm Water
Programs of Other Local Governments provided by the City of Fort
Worth
Phase II requires the cities (MS4s) to implement 6 programs. Their applications have to be in by March, 2003 and fully implemented by March, 2005. The get the most "bang" for the "buck" with program number one which is to be implemented first which is public education. They are:
Public Education and Outreach in the above means: Brochures, public meeting, trade shows exhibits and presentations, newspaper inserts, newspaper articles, public notices, inserts with water and trash bills, classroom lectures, programs to neighborhood associations, etc. See the Fort Worth NPDES Annual Report for an example of what all they did.
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
- 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
- 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.
Notice that Item No. 1, 9, 10, & 11 will require the capture and proper disposal of Power Wash Wastewater, and cleaning up of the wash area so there is no residue from wash operations. This should allow a "No Exposure Exclusion".
Phase II, "Illicit Discharge Detection and Elimination Minimum Control Measures" is composed of 5 sections:
Target dates for completion are:
Phase II, Sources of Illicit Discharges listed in table 1:
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.
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. Communities are going to be responsible for their Stormwater Discharges through their NPDES Permits. If communities do not provide an economical place for wastewater discharge then this activity will be done nights and weekends to avoid detection. These illegal discharges will end up in the storm sewer. Sooner or later communities will open up their POTWs to these wastewater discharges in order to control them. They are going to be forced into this position by their NPDES Permits.
Power Washers of North America (a national association of power wash contract cleaners,www.pwna.org) formerly requests the priviledge of submitting comments on proposed regulations or BMPs. Please forward them to:
Robert M. Hinderliter, PWNA
Environmental Chairman
%Delco Cleaning Systems of Fort Worth
2513
Warfield Street, Fort Worth, Texas 76106-7554
Phone: 800-433-2113, Fax:
817-625-2059, Email: robert@dcs1.com
MultiTech Environmental Mobile Power Wash System
Delco's PressureWashers ,
Delco's
Master Site Index ,
Home
Page , E-Commerce
Website
These photos may be used by Regulation Agencies provided the following is done:
