EPA Region 6 MS4 Ordinances for Pressure Power Wash Cosmetic Cleaning presented in Waco, TX July 15, 2008. Summaries the Cosmetic Cleaning Ordinances of EPA Region 6 and there effect on the pollutants in the Storm Drains.

1. MS4 Ordinances for Cosmetic Cleaning BMPs & Regulations for Mobile Power Wash Cosmetic Cleaning 10 th Annual EPA Region 6 MS4 Operator Conference July 15, 2008 Waco, Texas by Robert M. Hinderliter Environmental Chairman of PWNA & UAmCc President of Delco Cleaning Systems 1-800-433-2113 Copyright ©2008, Delco Cleaning Systems of Fort Worth, All Rights Reserved

12. Reality of Enforcement What Regulators are actually enforcing. What the results of various regulations are. What Contract Cleaners are actually doing. Ways to increase compliance.

25. Typical Power Washing Pollution Typical pollutants in waste washwater that Mobile Power Wash Contractors typically encounter are: Detergents Fats Oils Grease Gasoline Solids Solvents Heavy Metals Herbicides Insecticides Pesticides Total Dissolved Solids Anti-Freeze Emulsified Oil High pH levels caused by Acid Brighteners Fertilizers

27. EPA’s Responsibilities for Stormwater discharge The Environmental Protection Agency ( EPA ) does not provide written endorsements of products, processes, or technology . The EPA responsibilities are directed at setting specific objectives (discharge limits) that dischargers must meet to adequately protect receiving waters of the United States. These objectives will necessarily vary from site to site. If anyone tells you a product is EPA approved (like detergents) 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. EPA set the standards for cities and states thru their National Pollution Discharge Elimination System Program (NPDES Permits).

28. Cities Are Responsibilities for Stormwater Discharge Through their NPDES Permit Requirements (N ational P ollution D ischarge E limination S ystem ) Each city can decide 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!

31. Combined Total Discharge A city is responsible for the combined total discharge of their storm water per their NPDES Permit. It is not uncommon for municipalities to give exemptions to some companies. Some (including Kitchen Exhaust) contract cleaners have been able to get these exemptions and discharge wash water to the storm drains. These discharges to storm drain have been insignificant when combined with the total storm drain discharge of the municipality. Note: These discharge permits are not a release from liability for damage to the storm drains from these discharges! If the discharges causes problems in State of Federal Waters they are liable for the clean up.

32. sanitary and storm water Treatment 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. St. Louis, Indianapolis, Sacramento, and San Francisco are examples of cities that treat all of their wastewater in certain portions of the cities through their Combined Sewer System . Most cities go to the point source and require remediation before discharging to the sanitary sewer. It is significantly less expensive for the cities to require point source remediation than to remediate the pollution at their POTW’s.

35. 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 through a Hot Line . 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 . Two municipalities that have full time Cosmetic Cleaning Enforcement Offers are: San Diego, CA and Houston, TX.

39. Basic BMPs Cosmetic Mobile Power Washing in the most basic terms are: * No off property discharge * Directing the waste wash water to sanitary sewer. *Nothing down the Drain but Rain!

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

44. 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 Texas and most other states it is 220 pounds per month). To date I am not aware of any contractor that has be affected by this requirement. The EPA does not define Hot Water . Some regulators define it as any water that is elevated in temperature from the tap or outlet. This temperature can vary greatly. In the City Fort Worth we were able to define Hot Water as any water above 110  F.

45. 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 . The Regional Director of EPA Region 6 gave me the following example: A dead horse in a stream is biodegradable but it will kill the stream with all of the decay! The Term “Biodegradable” simply means that the product will not harm bacteria in the sewage treatment plant (POTW) and that it breaks down faster than more conventional products.

46. Waste Water Discharge The discharge to the Municipal Sanitary Sewer Systems by Contract Cleaners is insignificant when compared to the total volume that a Municipality processes. Usually “ Hazardous Waste” cannot be discharged to the POTW. No off property discharge hazards: 1) soil contamination, ground water contamination, and air contamination. May require soil remediation when property is sold or ground water remediation if contamination becomes known.

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

53. Water Dams control the waste water for pickup by a sump pump. The waste water passes through a wire screen filter before entering a holding tank. Then waste water is discharged to a sand trap by gravity flow.

54. Note that there is no oil sheen after the oil absorbent booms. The vacuum sludge filtering systems contain a bag filter and automatic discharge pump. The vacu-boom picks up 100% of the waste water.

55. A Steel Eagle Concrete (Surface) Cleaner with vacuum attachment for recovery of the waste water. This requires hook to both a pressure washer and a heavy industrial vacuum. This makes pick of the waste water and cleaning a one step operation.

56. A filter tub for cleaning kitchen grease exhaust grease filters. This job location was for a restaurant on a barge. No waste water enter the lake. The Filter Tub was hooked up to a Vacuum Sludge Filtering System at the bottom which discharged the waste water to a holding tank on shore.

57. A water dam for storm drain sealing, an oil absorbent boom for hydrocarbon removal, a window screen on the bottom of the sump pump for debris and sludge removal, and a sump pump for discharge to the sanitary sewer. Legal for sanitary sewer discharge in the City of Fort Worth, Texas for Cosmetic Cleaning.

58. Never discharge waste water to Storm Drains and Sanitary Sewers by removing the covers in the middle of the streets. They are city property!

59. An example of a Sanitary Sewer Clean Out Port. This is private Property and an acceptable discharge conveyance for waste water in the City of Fort Worth, Texas.

60. An example of a Storm Drain Blockers

61. Washing on a portable tarp in 1991 for waste water capture. Note the sump pump in the far right corner of the tarp. Every wrinkle in the tarp is a little water dam for dropping out of the sludge and debris on the tarp which is picked up with a plastic scoop shovel.

62. A child's wading pool filled with water that is higher than the surrounding waste water will effectively seal a storm drain. It does not look professional but is effective!

63. The storm drain is sealed, waste water passes through an oil absorbent boom for removal of hydrocarbons and a window screen (around the bottom of the sump pump) for removal of debris and sand is legal to discharge to sanitary sewer in many jurisdictions including Fort Worth, Texas!

64. Many jurisdictions are accepting cosmetic cleaning waste water that passes through an oil absorbent boom and a screen for discharge into the sanitary sewer and storm drains!!!! Not rocket science!

65. A Vader I Mobile Trailer Brush Wash Rig that captures the waste water for mobile recycling of the wash water during washing, then discharging the waste water to a sand trap.

66. Note the Vacuum Boom around the helicopter for waste water capture.

67. An example of a Latimat Wash Pad with air berms.

68. An example of total recycling wash rig.

69. A Vacu-boom advertisement for their waste water capture systems.

70. An example of waste water capture for Kitchen Grease Exhaust Cleaning.

71. An example of waste water filtration system using commercial vacuum cleaners. The waster water enters the top and drops through a bag filter for debris and solids removal before automatic discharge. If an oil absorbent boom is placed before the intake hose then the waste water will be acceptable for many jurisdictions to be discharged into the sanitary sewer.

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

75. The Cosmetic cleaner was given access to 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 (private property). Discharging through a 400 micron filter to remove the grit and sludge 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. Discharges into manholes are strictly forbidden, no matter where they are located. (city property)

76. Cosmetic Cleaners that utilize wash water recycling units fit into "process water" category and must test their effluent at least once annually. $50.00 Permit Fee for first Wash Rig. The fee for the permit (which goes to the business) is $25.00. The fee for the registration certificates is $25.00 per wash unit is to displayed on each wash rig. 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. 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.

77. Fort Worth Cosmetic Registration

78. Offenses are punishable by a fine of up to $2,000 per day per offense. Hot water is defined as any water over 110°F. 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. 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."

79. What did the Fort Worth Ordinance Miss? 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.

82. Fort Worth Regs Effectiveness

92. Oklahoma City

95. Who is an Environmentalist? Everybody is an “Environmentalist”! However, how one interprets that is usually based on how it affects their “economic revenue stream” (income, wages, business revenue). An Environmental Regulator brought this information to my attention. Example: A large segment of the “Coin-op car wash industry” believes that home owners should not be exempt for car washing discharge to storm sewer as this creates a large source of pollution to our storm sewers. This also holds true for charities (churches, girl scouts, boy scouts, etc). Because of Political Activity by the Coin-Op Car Wash Association (with a $500,000.00 budget) the San Diego Regional Water Quality Control Board banned charity washing during February of 2001 .

104. www.basmaa.org