Charlotte BMPs 4-19-09

Management of Wash Water Runofffrom Pressure Washing and Vehicle Detailing

*

BMPs for Containment/Disposal*

Charlotte-Mecklenburg Utilities, NC by

Robert M. HinderliterEnvironmental Consultant, United Association of Contract Cleaners

www.uamcc.orgPresident, Delco Cleaning Systems of Fort Worth

2513 Warfield Street, Fort Worth, Texas 76106-7554Phone: 800-433-2113, Fax: 817-625-2059www.dcs1.com , www.pressurewash.com

Note: The products and/or methods shown or depicted in this seminar may be covered by U.S. Letters of Patent.Copyright 2009, Delco Cleaning Systems of Fort Worth, All Rights Reserved

Thank You

• UAMCC and Contract Cleaners wish to express our appreciation to the City of Charlotte and Mecklenburg County for their willingness work with the industry in developing these BMPs.

• This is the first of several workshops

Clean Water Act

Nothing Down the Drain But Rain

Basic Rules of the CWA •The CWA prohibits a point source discharge of pollutants into waters of the United States without an NPDES Permit.

•If your discharge wash water does not reach waters of the United States, there are no requirements under the CWA. No Off Property Discharge.

•No Oil Sheen on discharged wastewater.

•Discharge only “Drinking Water Quality” wastewater to the storm drain.

•The Generator is responsible for “Cradle to Grave” of his waste.

• It is unlawful for any person to discharge any pollutant from a point source into navigable waters of the state.

•Private citizens can sue the government or other private citizens for violation of the CWA.

•The EPA can delegate many of the permitting, administrative, and enforcement aspects of the CWA to the states. The state then becomes a “Designated State”. North Carolina is a “Designated State”.

•The EPA Authorizes the “Superfund” to clean up uncontrolled or abandoned hazardous-waste sites, or other releases of pollutants.

•The CWA authorizes the EPA to seek out parties responsible for any releases into the environment and assure their cooperation in the cleanup.

•The EPA is authorized to recover costs from viable individuals and companies for cleanup.

•The EPA does not approve products, processes, or technology but sets specific discharge objectives that dischargers must meet.

•Regulators investigate complaints on a decrensary basis.

•The CWA says that you cannot dilute your discharge with water to achieve Discharge Limits.

Terminology1. 1. The EPA is very specific when it comes to

classifying Waste Wash Water: “Waste Wash Water is considered a source of Industrial Waste”.

2. 2. “Process Water” means any water, which during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product.

3. 3. “Pollutant” means dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into water.

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: Municipal Separate Storm Sewer System (Storm Sewer System. Includes storm sewer pipes, street, gutters, and drain ditches along the highway if they empty into waters of the state.)

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 Storm Drain System that is not composed entirely of storm water with some exceptions.

13. FOG: Fats, Oil, Grease

  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

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 if required!

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

EPA’s Responsibilities for Stormwater discharge 

The Environmental Protection Agency (EPA) does not provide written endorsements of:•Products•Processes•technology.

The EPA responsibilities are directed at setting specific objectives (discharge limits) that dischargers must meet (Charlotte Mecklenburg Utilities) to adequately protect receiving waters of the United States. These objectives will necessarily vary from site to site. 

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” (North Carolina 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.

Cities Responsibilities for Stormwater Discharge 

Each city decides 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!

The policies of Charlotte-Mecklenburg Utilities will probably be followed by the other local Phase II municipalities until they develop their own.

Phase I NPDES Permits were due:

•November 16, 1992 for cities over 250,000 population

•October 1, 1993 for cities over 100,000 population

(Note: A large number of Phase I Cities received 1 year or longer extensions of these dates.)

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 populationUnder 50,000 population if notified by the AHJ because of a significant environmental problem.

NPDES PERMIT SYSTEM • Contamination caused by rainwater was considered to be an act of God.

•This attitude was destroying our natural resources.

• EPA took control of the situation through their NPDES

•For the first time Business, Industry, and Government Bodies were going to be responsible for the pollution that rainwater washed off their property.

•The NPDES Program was implemented in two sections for municipalities

•Phase I

•Phase II

Phase II Phase II requires the cities 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:

1. Public Education and Outreach

2. Public Involvement and Outreach

3. Illicit discharge detection and elimination

4. Construction site runoff control (one acre and larger)

5. Post construction storm water control

6. Pollution Prevention and Good house keeping operations for the municipality.

Public Education and Outreach in the above means

•Brochures

•public meeting

•trade shows exhibits

•Presentations

•newspaper inserts

•newspaper articles

•public notices

•inserts with water and trash bills

•classroom lectures

•programs to neighborhood associations, etc.

Phase II, Sources of Illicit Discharges listed in table 1: 

•Sanitary wastewater

•Effluent from septic tanks

•Car wash wastewaters (FOG and Surfactants)

•Improper oil disposal

•Radiator flushing disposal

•Laundry wastewater (FOG and Surfactants)

•Spills from roadway accidents

•Improper disposal of auto and household toxics

These regions may do their NPDES Permits by themselves, combine or hire outside agencies to apply for their NPDES Annual Permits.

Charlotte is a Phase I Municipality

•Phase II Co-Permittees•Mecklenburg County

•Cornelius

•Davidson

•Huntersville

•Matthews

•Mint Hill

•Pineville

Other Phase II in the Metro Area

• Belmont, Concord, Cramerton, Dallas, Harrisburg, Hemby Bridge, Gastonia, Indian Trail, Kannapolis, Marvin, Monroe, Lowell, McAdenville, Mt. Holly, Ranlo, Stallings, Weddington, Wesley Chapel, Cabarrus Co, Gaston Co, Union Co

NPDES Permit ViolationA violation of their NPDES Permit because of detergents & FOGs will move waste wash water discharges to the Storm Drain to the top of the list.

Presently Charlotte-Mecklenburg Utilities is having to report Surfactants, Fats, Oil, and Grease Levels every 6 months to the EPA instead of yearly. 

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. Charlotte-Mecklenburg Utilities goes to the point source and require remediation before discharging to the sanitary sewer. It is significantly less expensive to require point source remediation than to remediate the pollution at their POTW.

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 and have a hot line for complaints and reports of violations.

Authority Having Jurisdiction (AHJ)

Where wash water is discharged determines what Regulatory Agency you must deal with. Discharge locations are: 

   Ground Water

   Surface Water

    Sanitary Sewer or the POTW

    Private or Commercial Disposal Facility 

Charlotte-Mecklenburg Contacts

• City of Charlotte Storm Water Services, Craig Miller, (704) 336-7605

• Mecklenburg County Storm Water Services, Rusty Rozzelle, (704) 336-5449

• Charlotte-Mecklenburg Utilities, Regina Cousar, (704) 336-4962

Charlotte Mecklenburg Hot Line

• Non-Emergency Hot Line 311 goes to the City/County Customer Service which refers Environmental Calls to the appropriate agency for investigation.

Typical Power Washing Pollution

Typical pollutants in waste washwater that Mobile Power Wash Contractors typically encounter are:Detergents

FatsOilsGreaseGasolineSolidsSolventsHeavy Metals

HerbicidesInsecticidesPesticidesTotal Dissolved Solids Anti-FreezeEmulsified OilHigh pH levels caused by Acid BrightenersFertilizers

This photo was taken on April 3, 2009 and shows the storm drain near the Speedy Truck Wash where Metropolitan Sewer District of Louisville, KY claims that waste from washing pig trucks was sent. (from the Courier-Journal.com)

What sort of Hazardous Waste can a Mobile Power Wash Contract Cleaner generate?

• Oil Saturated Absorbents

•Wash water containing:

Solvent CleanersFats (Hazardous is some states)

Oil (Hazardous is some states)

Grease (Hazardous is some states)

Total Dissolved Solids

Heavy MetalsHerbicidesPesticidesInsecticides

Paint Chips containing lead, chromium, cadmium, or mercury.Lead from battery washing or engine degreasing.Emulsified Oils (Hazardous is some states)

High pH levels caused by Acid BrightenersAsbestos contamination from insulation, shingles, or siding.Anti-Freeze

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.

Example: A vehicle that has traveled through fresh road oil or asphalt.

Off property Discharge Liabilities

1. Surface Water Contamination

2. Ground Water Contamination

Basic Terms

Cosmetic Mobile Power Washing in the most basic terms is:

•No off property discharge to the Storm Drain System

•Directing the waste wash water to:•sanitary sewer

•On Site•Hauling off site

•Private Environmental Facility

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.

Discharge wash water to conveyance of most remediation: Sand traps, grease traps, oil/water separators, clarifiers, Utility Sinks, Clean-outs, inside floor drains, commodes, sinks, and Clean-Out Stubs 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.

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 North Carolina and most other states it is 220 pounds per month).

The EPA does not define Hot Water.

Charlotte Mecklenburg defines Hot Water as any water above 110F.

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.

Biodegradable generally means that it can be processed by the POTW (sewer treatment plant).

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.

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. 

Dry Washing

If a “dry” wash method is used, no wastewater is generated, so there is no discharge that would require a permit under the CWA.

Dry Cleanup Methods: In many cases you can eliminate the need to collect and/or divert wash water if you follow this two-step process:

•Use absorbent (such as rags, absorbent mats or pads, rice hull ash, cat litter, vermiculite, sand, and Oil Sorb) to pick up greasy or oily spills.

•Sweep or vacuum to pick up litter, debris, or saturated absorbents.

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.

Wash Areas: •Filter Tubs, Mop Sinks, Kitchen Sinks (For Grease Exhaust Filters)

•designated areas for water containment on a hard surface

•portable wash pits (flat vinyl tarps with PVC & 2x4 berms)

•wash pads (vinyl tarps with built in Air Berms)

•Wash Bays, metal containment pads. 

Some AHJs will not let you wash on asphalt because detergents are designed to emulsify the hydrocarbons in the asphalt. 

Regulators prefer that you do not transport used waste wash water between customers because the liability trail is broken. Under Risk Management scenario most Contract Cleaners do.

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.

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.

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

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.

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.

Used Wash Water Recovery

• Surface Cleaner Recovery Tool hooked up to a Truck Mounted Carpet Cleaner

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. Note the oil sheen before the Oil Absorbent Boom.

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

•1988. A child’s inflatable Vinyl Swimming Pool was used to stop up a Stormdrain and a sump pump was used to discharge directly to Sanitary Sewer in Seattle, Washington. This procedure was approved by the City of Seattle and was a Trade Secret at the time.

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.

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!

Remediation Example

• Childs wading pool drain blocker

• Sump pump with window screen filter

• Oil absorbent boom

Storm Drain Filter

Many companies are now making products similar to this.

Here a window screen and oil absorbent booms have been installed before the drain. The oil absorbent booms will remove the free oils and greases.

    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.

Canvas was very heavy when wet.

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. 

After washing is accomplished the wash area should be should be cleaned to prevent dirt, sludge, and debris being washed into the storm drain when it snows or rains.

The washing of Hauling Compartments (Interior of trailers and tankers) should be limited to non-hazardous inert and biodegradable materials.

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.

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

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.

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.

Simple Recovery Matt

Plastic Tarp, Shop Vac

Waste Ownership

Customer is owner of the waste from cradle to grave which is your Customer.

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.

Presently North Carolina does not regulate used non-hazardous wash water in public transportation.

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. 

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

An example of waste water capture and proper disposal.

Not Rocket Science!

Think, Imagine, Conceive, Action

An example of a Sanitary Sewer Clean Out Port.

Another example of a Sanitary Sewer Clean Out Port.

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.

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.

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

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.

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

Storm Drain the empty directly into Lake Tahoe

Beautiful Lake Tahoe

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.

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.

Low level technology clean up.

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.

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.

Grease Dumpster

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.

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. 

Discharge to Stormdrain should be free of visible foam and Oil Sheen.

Cold Water Washing

In most areas cold water washing with no chemicals is considered no worse than a rain event. Therefore cold water washing with no chemicals 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.

Common cold water jobs •Car lots (cars are to be clean before being placed on the lot)

•sidewalks

•shopping malls

•buildings exteriors

•homes

•parking lots

•garages

Kitchen Grease Exhaust Cleaning is Not a common cold water job. Any type of oil and grease cleaning is a common Hot Water job.

Common cold waterpower booster (replace chemicals): 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.

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. Preclean oil and grease spots.

Another example of zero degree rotating nozzles.

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.

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. 

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.

Dispose of your waste water from Kitchen Grease Exhaust Cleaning into the grease trap on site. Heavy deposits of grease should be appropriately collected (scraping for example) and deposited into a grease container or grease dumpster. Note: do not deposit grease into the garbage dumpster.

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.

Mobile Power Wash Recycling units do not remove:

•Detergents•totally dissolved solids•heavy metals• herbicides• insecticides•Pesticides•Solvents•anti-freeze•Emulsified Oil & Grease.

Mobile Power Wash Recycle Units

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 recycled 20 micron filtered water in order for the water to be 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.

• Most Contract Cleaners limit their recycling to one or two days then purge their recycle units of wastewater and refill with fresh water. This avoids the hazardous waste problem and produces a better quality wash. They wash with recycled water and rinse with fresh water.

• If you transport Hazardous Waste you will be required to obtain EPA Identification before transporting Hazardous Waste.

Contract Cleaner BMPs For Storm Drain Discharge

•Cold Water Only

•No chemicals, no visible foam

•Preclean oil and grease spots (kitty litter)

•No Oil Sheen, remediate through an oil absorbent boom

•No debris (Preclean debris [by sweeping or with a leaf blower], filter through a 40 mesh screen or 200 micron bag filter.

•Note: Hot water may be used in some jurisdictions for surfaces with no oil and grease contamination.

Typical Exemptions for

Stormdrain Discharge

Washing Activities that are commonly disposed to Storm Sewer (Typical exceptions): •Small fleets (1 to 8 vehicles) on grassy area done once or twice per month

•residential washing

•Charities

•new and used car lots

•residential homes (house washing and deck cleaning)

•cold water washing with no chemicals

•side walks and parking lots with hot water only if you pre-clean oil and grease spots with oil absorbent clay (put into dumpster)

•remediate your wash water with oil absorbent booms (be sure it is a nice pretty white clean one for image) and pass through a window screen to remove debris. Note: This is presently being accepted in a lot of Phase II Municipalities and Urban Areas.

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.

Use the same procedures as you would for “used oil”.

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.

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.

Reportable Quantity

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

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.

Underground Stormwater Detention/Retention by Cultec, Inc. These systems do not remediate your wash water for storm drain discharge.

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.

Usually “Hazardous Waste” cannot be discharged to the POTW.

If you do acid cleaning or two-step chemical cleaning you will need to batch process their wash water and neutralize it before discharging to the sanitary sewer.

No off property discharge hazards: 1) soil contamination, and ground water contamination. May require soil remediation when property is sold or ground water remediation if contamination becomes known.

Note: Discharging under these guidelines is not a release from liability if clean-up is required.

Drought Conditions• During drought conditions power washing cannot

be done except for health and safety conditions.• When power washing for health and safety

reasons you need to contact City of Charlotte Storm Water Services, Craig Miller, (704) 336-7605; Mecklenburg County Storm Water Services, Rusty Rozzelle, (704) 336-5449 before starting your work.

• Haul in your wash water from a legal area or use “grey water” from a local source.

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).

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.

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.

Charlotte Mecklenburg BMPs

• Always Preclean: do not discharge sand, dirt, and debris into the Sanitary Sewer or Storm Drain.

– Clean debris and dispose of properly up (sweeping, leaf blower, vacuum, etc).

– Preclean oil and grease spots with an oil absorbent and dispose of properly. Collect oil and grease accumulations for proper disposal.

• Always Filter Waste Water: To remove silt, sand, sludge, and debris filter through a 200 Mesh screen or smaller.

• To remove hydrocarbons filter through an oil absorbent filter or oil/water separator (oil absorbent boom, recycling system, sand trap, grit grease trap, clarifier, etc).

• Discharges to Environmental Waste Company:

• It is always acceptable to capture the waste water and dispose of through an Environmental Waste Company.

• Generally the most expensive option

Discharges to the Sanitary Sewer

• For discharges to the Sanitary Sewer (as indicated by a “Yes” in the table below) up to 1,000 gallons per day are allowed without prior approval. All other discharges are either not allowed or prior approval is required from Charlotte-Mecklenburg Utilities at (704) 336-4407.

• Discharges must be in compliance with local regulations and limits, and may require pre-treatment, sampling, permitting and/or other measures. Ensure pH of the waste water is between 6.0 and 12.0 (use pH test strips) and below 150˚F.

Discharges to the Storm Drains

• Never discharge detergents or chemicals to the Storm Drains;

• Washing with cold water and no chemicals is considered no worse than a rain event and may be discharged to the storm drains for surface that are not contaminated with oil and grease.

• Discharges should be free of visible foam and oil sheen.

Discharges to Landscaped Areas: For discharges to landscaped areas (as indicated by “Yes” in the table below) you must do the following:

• (a) Obtain the property owner’s permission;

• (b) ensure discharge volume is small enough that it soaks into the ground without running onto paved areas, generally limit your discharge to 1,000 gallons/acre per month;

• (c) do not discharge repeatedly to the same areas because doing so may contaminate soil/groundwater, damage plants and cause other nuisance conditions;

• (d) ensure pH of the waste water is between 6.0 and 9.0 (use pH test strips).

Conveyance to the Sanitary Sewer

Use the method of conveyance that removes the largest amount of containments that is available:

• Sand, Grit, or Grease Trap

• Oil/Water Separator

• If these options are not available then mop, utility, or kitchen sinks; toilets, inside floor drains; or Sanitary Sewer Clean-out Stubs.

• Never use Sanitary Sewer or Storm Sewer Covers.

• Discharge Limits: If satisfactory discharge limits cannot be reached with continuous waste water flow then use batch processing (holding tank). Like bringing the pH within acceptable limits.

• Biodegradable: Use biodegradable, non-toxic chemicals if possible. Note: Biodegradable does not mean non-toxic, it only means that it can be easily processed at a Sanitary Sewer Plant, it does not mean that it can be discharged to the storm drain.

• Hot Water & Detergents: Hot Water and Detergents are emulsifiers and the discharge is special waste.

• Waste Water Capture: Best – Use a permanent or portable containment pad to capture the waste water. 2nd – Seal the Storm Drains to capture the waste water. The technology to capture the waste water is the responsibility of the contract cleaner.

• Hot Water: Hot water is defined a temperature above 110˚F.

• Cosmetic Cleaning: These guideline for regular maintenance cosmetic cleaning and do not include hazardous waste.

• Release of Liability: Discharging to the Storm Drains, Sanitary Sewer, or Landscaping under these guidelines is not a release of liability if clean up or remediation is required.

Charlotte Mecklenburg Cosmetic Cleaning BMPs

Washing Activity

Conditions StormDrain

SanitarySewer

LandscapedArea

EnvironmentalWaste Company

Comments

Cold Water, No Chemicals,auto rinsing, homes, decks, side walks, buildings

To remove mainly dirt, surfaces without oil & grease

YESSee item #5

YESSee item #4

YESSee item #6

YESSee item #3

Preclean any oil & grease spots if any.

Hot Water, No Chemicals,auto rinsing, homes, decks, side walks, buildings

To remove mainly dirt, surfaces without oil & grease, no chemicals, with heat

YESSee item #5*

YESSee item #4

YESSee item #6

YESSee item #3

* May discharge to the storm drain with prior permission from Charlotte-Mecklenburg Utilities

Charlotte Mecklenburg Cosmetic Cleaning BMPs

Washing Activity

Conditions StormDrain

SanitarySewer

LandscapedArea

EnvironmentalWaste Company

Comments

Hot WaterChemicalsTrucks, autos, homes, buildings, flat work, machinery, aircraft, trains

To remove mainly dirt, & light amounts of Oil & Grease

No YESSee item #4

YESSee item #6

YESSee item #3

These items are not normally contaminated with heavy amounts of oil and grease.

Hot WaterChemicalsTrucks, autos, homes, buildings, flat work, machinery, aircraft, trains

To remove mainly dirt, & heavy amounts of Oil & Grease

No YESSee item #4

No YESSee item #3

Collect Oil and Grease accumulations and dispose of properly, as with Oil Filters

Charlotte Mecklenburg Cosmetic Cleaning BMPs

Washing Activity

Conditions StormDrain

SanitarySewer

LandscapedArea

EnvironmentalWaste Company

Comments

Hot WaterChemicalsDegreasing of Engines, Equipment,5th Wheels

To remove large amounts of grease

No No No YESSee item #3

Collect Oil and Grease dispose of properly, as with Oil Filters & to Environmental Waste Company

Hot WaterChemicals

Kitchen Grease Exhaust Cleaning

No YESSee item #4

No YESSee item #3

Large Amounts of Grease should be collected and put into the Grease Dumpster or disposed to Environmental Waste company, Waste Water disposed to the Grease Trap.

UAMCC’s Comments

• The BMPs are– Rational– Reasonable– Logical

• The sales of Environmental Equipment are not Regulatory Driven.

• The Contract Cleaner Can chose the level of investment from $300 - $3,000 – $15,000 depending on his choice to maximize his profits.

The End

• Thank you for your time and attention

Robert M. HinderliterEnvironmental Consultant UAMCC