StormCon R-80

BMPs and Regulations for Cosmetic Mobile Power Pressure Washing

Robert M. Hinderliter

Environmental Chairman, Power Washers of North America

6418 Grovedale Drive, #101-B, Alexandra, VA 22310-2571

Phone: 800-393-7962, Fax: 703-971-7772, Website: www.pwna.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

All cities over 100,000 in population, and all urban areas over 50,000, and some urban areas over 10,000 in population must now have a NPDES Permit to operate their storm drain systems (MS4s, Municipal Separate Storm Sewer System).

EPA NPDES Permits for cities and Urban Areas: Phase I for cities over 250,000 populations was due November 16, 1992; for cities over 100,000 populations was due October 1, 1993. A lot of cities received a one-year or more extension on these dates. Phase II Urban Areas should not expect this leniency as they have the Phase I Cities experiences and examples to draw upon.

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)

These NPDES Permits allow only storm water to be discharged to the MS4 and require an illicit detection and elimination program for non-storm water discharges. Included in this program is detergent detection and elimination. Phase I Cities have determined that detergents are the number one pollutant in MS4s in many cases. And Mobile Power Wash Contract Cleaners are a significant source of detergents and other pollutions including: fats, oil, grease, solvents, and emulsified oils.

Economics of Detergent Control and Regulation

Various approaches have been tried by municipalities to control the effluent from Mobile Power Washing. This has included an out right ban on power washing to lenient discharge requirement to the sanitary sewer. A popular measure is to require the capture of the discharge from mobile power washing without an approved disposal site, “No Off Property Discharge”. Often time this approach does not leave the contract cleaner with an economical disposal site and discharges are directed to the storm drains.

Reality of Enforcement

For most areas effluent discharge from mobile power washing activities is insignificant when compared to the total storm water discharge. Normally the Enforcement Budget has items of more importance than power washing activities. Therefore in most areas enforcement is done on a complaint basis only.

Very few municipalities have an officer assigned to the enforcement and regulation of Mobile Power Washing Activities. Unless enforcement is done on a 24/7 basis it merely diverts this activity to nights and weekends.

Entry into the Power Wash Business requires a minimal investment now as entry level pressure washers can be purchased at consumer and hardware stores, such as Sears, Home Depot, and Lowe’s. The least expensive of these units can be purchased for under $100.00. This means that almost anyone with a vehicle and the desire can be in the Mobile Power Wash Business. Often times Power Washing is a part time business done on nights and weekends when enforcement is at its lowest.

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).

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.

As Environmental Chairman of PWNA I have had several instances where the local Environmental Regulator stated the high level of compliance that had been established in their area only to go out that night and drive down the freeways and observe otherwise!

Effect of Environmental Regulations on Cosmetic Mobile Power Washing

At the present time there is over 10 years of compliance history to draw from Phase I Municipalities. The industry has proven that there will be a high level of compliance if the regulations are:

· Reasonable

· Rational

· Logical

And if the Regulations are not reasonable, rational, and logical there will be a high level of non-compliance on nights and weekends.

The question then becomes “How to achieve the highest level of compliance with the least amount of expense to the municipality and urban areas?”.

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.

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.

High Lights of the Fort Worth Code: DIVISION 2, COSMETIC CLEANING

1) 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

2) 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.

3) 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.

4) 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.

5) Discharges into manholes are strictly forbidden, no matter where they are located.

6) Cosmetic Cleaners that utilize wash water recycling units fit into "process water" category and must test their effluent at least once annually.

7) The fee for the permit (which goes to the business) is $25.00.

8) The fee for the registration certificates is $25.00 per wash unit.

9) 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.

10) 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.

11) Offenses are punishable by a fine of up to $2,000 per day per offense.

12) Hot water is defined as any water over 110°F.

13) 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.

14) 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: 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

BASMAA’s Pollution Prevention Voucher

Portable Dam, Sump Pump, Wire Mesh Filter Recovery Tank

Discharging to Sand Trap          Vacuum Sludge Filtering System, Oil Absorbent
                                                       Boom, Vacuum Boom, Portable Dam

Vacuum Recovery Filter Cleaning Tub for Kitchen Grease Exhaust Filters
Concrete Cleaner

Portable Dam, Screen Sump Pump,          Washing Coca Cola Trucks on a Portable Wash Pit
Oil Absorbent Boom

Child’s Wading Pool used to stop up a                Oil Absorbent Booms, Window Screen, Storm
a Storm Drain, Oil Absorbent Boom,                   Drain or Sand Trap, No Oil Sheen
Screen Sump Pump, No Oil Sheen

Vader Mobile Brush Truck Wash Unit with water               Multi-Tech Environmental Mobile
capture capability for discharging to the Sand Trap.           Power Wash Recycling System

Vacu-Boom and Vacuum Kitchen Grease Exhaust Cleaning Waste Water Capture

Sludge Filtering Unit for Two Vacuums           Sludge Filter    Grease Exhaust Fan with Grease
                                                                                                         Capture Trough