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Management of Wash Water Runoff from Pressure Washing and Vehicle Detailing * BMPs for Containment/Disposal * Charlotte-Mecklenburg Utilities, NC   by Robert M. Hinderliter Environmental Consultant, United Association of Contract Cleaners www.uamcc.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 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 ,[object Object],[object Object]
Clean Water Act ,[object Object]
Basic Rules of the CWA   ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
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Terminology ,[object Object],[object Object],[object Object]
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 :  M unicipal  S eparate  S torm  S ewer  S ystem (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).
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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.
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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 population Under 50,000 population if notified by the AHJ because of a significant environmental problem.
NPDES PERMIT SYSTEM   ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
Phase II   ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
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NPDES Permit Violation A 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)   ,[object Object],[object Object],[object Object],[object Object],[object Object]
Charlotte-Mecklenburg Contacts ,[object Object],[object Object],[object Object]
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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
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)
[object Object],[object Object],[object Object],Solvent Cleaners Fats  (Hazardous is some states) Oil  (Hazardous is some states) Grease  (Hazardous is some states) Total Dissolved Solids Heavy Metals Herbicides Pesticides Insecticides 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 Brighteners Asbestos 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.
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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 110  F.
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   ,[object Object],[object Object],[object Object],[object Object]
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.
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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.
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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.
 
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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!
[object Object],[object Object],[object Object],[object Object],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.
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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.
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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.
[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],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.
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Typical Exemptions for Stormdrain Discharge   ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
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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.
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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 ,[object Object],[object Object],[object Object]
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Charlotte Mecklenburg Cosmetic Cleaning BMPs * May discharge to the storm drain with prior permission from Charlotte-Mecklenburg Utilities YES See item #3 YES See item #6 YES See item #4 YES See item #5* To remove mainly dirt, surfaces without oil & grease, no chemicals, with heat Hot Water,  No Chemicals, auto rinsing, homes, decks, side walks, buildings Preclean any oil & grease spots if any. YES See item #3 YES See item #6 YES See item #4 YES See item #5 To remove mainly dirt, surfaces without oil & grease Cold Water,  No Chemicals, auto rinsing, homes, decks, side walks, buildings Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain  Conditions  Washing Activity
Charlotte Mecklenburg Cosmetic Cleaning BMPs Collect Oil and Grease accumulations and dispose of properly, as with Oil Filters YES See item #3 No YES See item #4 No To remove mainly dirt, & heavy  amounts of Oil & Grease Hot Water Chemicals Trucks, autos, homes, buildings, flat work, machinery, aircraft, trains These items are not normally contaminated with heavy amounts of oil and grease. YES See item #3 YES See item #6 YES See item #4 No To remove mainly dirt, & light amounts of Oil & Grease Hot Water Chemicals Trucks, autos, homes, buildings, flat work, machinery, aircraft, trains Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain  Conditions  Washing Activity
Charlotte Mecklenburg Cosmetic Cleaning BMPs 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. YES See item #3 No YES See item #4 No Kitchen Grease Exhaust Cleaning Hot Water Chemicals Collect Oil and Grease dispose of properly, as with Oil Filters & to Environmental Waste Company YES See item #3 No No No To remove large amounts of grease Hot Water Chemicals Degreasing of Engines, Equipment, 5th Wheels  Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain  Conditions  Washing Activity
UAMCC’s Comments ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
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Charlotte BMPs 4-19-09

  • 1. Management of Wash Water Runoff from Pressure Washing and Vehicle Detailing * BMPs for Containment/Disposal * Charlotte-Mecklenburg Utilities, NC   by Robert M. Hinderliter Environmental Consultant, United Association of Contract Cleaners www.uamcc.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 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  
  • 2.
  • 3.
  • 4.
  • 5.
  • 6.
  • 7. 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 : M unicipal S eparate S torm S ewer S ystem (Storm Sewer System. Includes storm sewer pipes, street, gutters, and drain ditches along the highway if they empty into waters of the state.)
  • 8. 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.
  • 9. 13. FOG : Fats, Oil, Grease
  • 10.     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
  • 11. 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!
  • 12. EPA set the standards for cities and states thru their National Pollution Discharge Elimination System Program (NPDES Permits).
  • 13.
  • 14. 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.
  • 15. 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.
  • 16.
  • 17. 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 population Under 50,000 population if notified by the AHJ because of a significant environmental problem.
  • 18.
  • 19.
  • 20.
  • 21.
  • 22.
  • 23.
  • 24. NPDES Permit Violation A 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. 
  • 25. 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.
  • 26. 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.
  • 27.
  • 28.
  • 29.
  • 30. 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
  • 31. 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)
  • 32.
  • 33. 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.
  • 34.
  • 35.
  • 36. 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.
  • 37. 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.
  • 38. 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 110  F.
  • 39. 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).
  • 40. 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.
  • 41. 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.  
  • 42.
  • 43. 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.
  • 44.
  • 45. 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.
  • 46. 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.
  • 47. A Portable Dam sealing off a storm drain, and a sump pump with a window screen filter for discharge to a sand trap.
  • 48. 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.
  • 49. 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.
  • 50.
  • 51. 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.
  • 52. Note the berm for wash water containment and the sump pump pit in the lower left hand corner of the wash pad.
  • 53.  
  • 54.
  • 55. 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.
  • 56. 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!
  • 57.
  • 58. 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.
  • 59.       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.
  • 60. Canvas was very heavy when wet.
  • 61. 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.
  • 62. 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.
  • 63. Draping a for a roof fan cleaning. Discharge to Sanitary Sewer.
  • 64. 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.
  • 65. 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.
  • 66.
  • 67. Waste Ownership Customer is owner of the waste from cradle to grave which is your Customer.
  • 68. 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.
  • 69. 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. 
  • 70. 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”.
  • 71. An example of waste water capture and proper disposal. Not Rocket Science! Think, Imagine, Conceive, Action
  • 72. An example of a Sanitary Sewer Clean Out Port .
  • 73. Another example of a Sanitary Sewer Clean Out Port.
  • 74. 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.
  • 75. 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.
  • 76. Waste Water was discharged to the restaurant’s septic system by gravity flow under supervision of the chef.
  • 77. 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.
  • 78. 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
  • 79. Storm Drain the empty directly into Lake Tahoe Beautiful Lake Tahoe
  • 80. 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.
  • 81. 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.
  • 82. Low level technology clean up.
  • 83. 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.
  • 84. 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
  • 85. 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.
  • 86. 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.
  • 87. 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.
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  • 89. 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.
  • 90. 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.
  • 91. 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.
  • 92. 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.
  • 93. 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.
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  • 95. 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.
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  • 100. 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”.
  • 101. 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.
  • 102. 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.
  • 103. 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.
  • 104. 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.
  • 105. Underground Stormwater Detention/Retention by Cultec, Inc. These systems do not remediate your wash water for storm drain discharge.
  • 106. 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.
  • 107. 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.
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  • 109. 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).
  • 110. 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.
  • 111. 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.
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  • 122. Charlotte Mecklenburg Cosmetic Cleaning BMPs * May discharge to the storm drain with prior permission from Charlotte-Mecklenburg Utilities YES See item #3 YES See item #6 YES See item #4 YES See item #5* To remove mainly dirt, surfaces without oil & grease, no chemicals, with heat Hot Water, No Chemicals, auto rinsing, homes, decks, side walks, buildings Preclean any oil & grease spots if any. YES See item #3 YES See item #6 YES See item #4 YES See item #5 To remove mainly dirt, surfaces without oil & grease Cold Water, No Chemicals, auto rinsing, homes, decks, side walks, buildings Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain Conditions Washing Activity
  • 123. Charlotte Mecklenburg Cosmetic Cleaning BMPs Collect Oil and Grease accumulations and dispose of properly, as with Oil Filters YES See item #3 No YES See item #4 No To remove mainly dirt, & heavy amounts of Oil & Grease Hot Water Chemicals Trucks, autos, homes, buildings, flat work, machinery, aircraft, trains These items are not normally contaminated with heavy amounts of oil and grease. YES See item #3 YES See item #6 YES See item #4 No To remove mainly dirt, & light amounts of Oil & Grease Hot Water Chemicals Trucks, autos, homes, buildings, flat work, machinery, aircraft, trains Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain Conditions Washing Activity
  • 124. Charlotte Mecklenburg Cosmetic Cleaning BMPs 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. YES See item #3 No YES See item #4 No Kitchen Grease Exhaust Cleaning Hot Water Chemicals Collect Oil and Grease dispose of properly, as with Oil Filters & to Environmental Waste Company YES See item #3 No No No To remove large amounts of grease Hot Water Chemicals Degreasing of Engines, Equipment, 5th Wheels Comments Environmental Waste Company Landscaped Area Sanitary Sewer Storm Drain Conditions Washing Activity
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Notas do Editor

  1. Remind everyone to turn off their cell phones.