ENVIRONMENTAL MOBILE POWER WASHING
(Reality of Enforcement, December 18,1995) Last update: March 15, 1999 Written By Robert M. Hinderliter Edited by Don E. Kerzee, Larry Hinckley, Greg Foster, & Michael Hinderliter of Powerwash.com 2513 Warfield Avenue, Fort Worth, Texas 76106-7554 Canada/U.S. Wats: 800-433-2113 Fax: 817-625-2059
REPORT NO. 507 Copyright , Powerwash.com All rights reserved FORWARD
- This article is written from the stand point of what is economically feasible for the Mobile Power Wash Contractor to implement in plain English for the washing of items not contaminated by hazardous material. This article does not include hazardous washing and cleaning.
- Complying with Environmental Power Washing Regulations is fairly simple. DISPOSE OF ALL OF YOUR WASH WATER TO SANITARY SEWER. The hard part comes from all the variations in applying this simple procedure. No one answer works in all locations, you will need a lot of tools and techniques you can call on.
- DVD 504, Fleet Washing with Portable Wash Pits and Portable Recycling Systems, demonstrates these Environmental Power Washing Procedures for Truck Washing. (the products and/or methods shown or depicted in this video may be covered by Letters Patents.)
Environmental Power Washing Environmental Mobile Power Washing is the proper environmental disposal of your used wash water. Exactly what this is will be defined on a local basis, usually by the Local Municipality. Mobile Power Wash Recycling is but one of the many techniques used to meet this criteria. Copyright , Powerwash.com of Fort Worth. All rights reserved.
TABLE OF CONTENTS
- The EPA and Environmental Compliance
- Storm Water Permits
- No off property discharge
- Sewer Type
- A. Sanitary Sewer
- B. Storm Sewer
- C. Combined Sewer
- Wash Areas
- A. Wash Bay
- B. Hard Surface
- C. Confined Area
- Portable Vinyl Wash Pit
- Bermed Area on Hard Surface
- Disposal of Wash Water--Sanitary Sewer
- Discharge to a Sand Trap (Clarifier, Coalescers, Oil/Water Separator, or Grease Trap)
- Truck Wash
- Coin-op Car Wash
- Install your own sand trap
- Restaurant Grease Trap
- Pre-treat wash water and discharge directly to sanitary
- Commercial Disposal Site
- POTWS and POTW discharge limits
- Discharge to a Sand Trap (Clarifier, Coalescers, Oil/Water Separator, or Grease Trap)
- Disposal of Wash Water to Storm Sewer
- A. No Hot Water
- B. No Chemicals including all soaps and acid cleaners
- C. Do not flush Hydrocarbons, Antifreeze, Insecticides or Pesticides to storm drain, clean with absorbent material dispose of properly.
- E. Strain out dirt and leaves
- F. Dry pre-clean and sweep
- G. Neutralize acid with sodium bicarbonate (baking soda) or Sodium Carbonate (soda ash) or caustic detergent wash
- H. Pass wash water through an oil absorbent filter, no oil sheen past the filter
- I. Examples: Vehicles on Dealer Lots, Sidewalks, Parking Lots, Shopping Malls, Buildings, and Homes.
- Recycle Wash Techniques
- A. Vehicles
I. 30% to 50% Loss due to Evaporation and Drag Off
II. Fresh Water Rinse
- B. Flat Work
- C. Limited Recycling, 8 to 16 hours
- Sludge Disposal Options
- Hydrocarbon Disposal (used oil)
- Hazardous Classification
- Waste Ownership
- Wash Water Management
- A. Direct Discharge Units (DDU)
- B. Waste Water Haulers (WWH)
- C. Pretreatment Units (PU)
- D. Limited Recycle Units (LRU)
- F. Total Recycling Units (TRU)
- What Your EPW Customers will require
- A. Letters of Approval of your EPW Procedures
- B. Letters of Acceptance of your EPW waste
- Risk Management
- Opportunity speaks, are you listening?
ACRONYMS and DEFINITIONS BOD--Biochemical Oxygen Demand BMP--Best Management Practices COD--Chemical Oxygen Demand EPA--Environmental Protection Agency FOG--Fats, oils, and greases Heavy Metals: Arsenic, Barium, Boron, Cadmium, Chromium, Copper, Lead, Manganese, Mercury, Nickel, Selenium, Silver, Zinc mg/l--Milligrams per liter MS4--Municipal Separate Storm Sewer System (Storm Sewer, i.e. Storm Drain) NPDES--National Pollution Discharge Elimination System Portable Vinyl Wash Pit--Is a Flat Tarp Portable Vinyl Wash Pit. POTW--Public Owned Treatment Works (Sanitary Sewer Plant) Sand trap--may be: Coalescer, Clarifier, Oil/Water Separator, Grease Trap, or Grit Trap Storm Drain--Replaces the Term Storm Sewer because of confusion by the public TCLP--Toxicity Characteristic Leaching Procedure extract TNRCC--Texas Natural Resource Conservation Commission TPH--Total Petroleum Hydrocarbons TSS--Total Suspended Solids
- THE EPA AND ENVIRONMENTAL COMPLIANCE
Off property discharge of Vehicle Wash Water is a violation of the Clean Water Act. Daily fines can be: Cities--$2,000.00 per day, States--$10,000.00 per day, and the EPA--$25,000.00 per day. The American Trucking Association had their first ever National Conference on Environmental Vehicle Washing April 6 & 7, 1995 in Fort Lauderdale, Florida. Powerwash.com was a sponsor of that seminar.
- 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.
- So where does this leave the Mobile Power Wash Operator? Basically it means that the City and County Governments deal with the EPA and State Regulatory agencies with the discharge of their Sewer Treatment Plants (POTWS) and Storm Water. And the Mobile Power Wash Operators must deal with the City and County Governments. Each POTW (Public Owned Treatment Works) must meet specific guidelines set by the EPA. Also each City must meet specific discharge objectives for their Storm Water runoff. The EPA does not specify how these discharge objectives are going to be met. Each POTW or City can decide what technology, products and procedures they are going to use to meet the EPA Guidelines. This means that rules for Environmental Power Washing will vary from City to City and sometimes from site to site within the same city.
- If Wash Water is recycled long enough it will test hazardous and have to be disposed of at a hazardous waste facility and you may have to obtain a Hazardous Waste Generator Permit. This is not economically feasible. What is economically feasible is to recycle the wash water for a short period to time and discharge it to the sanitary sewer within sanitary sewer discharge limits. These limits will vary from site to site. What most Environmental Mobile Wash Operators are doing is limiting their washing activities so that they do not enter the hazardous classifications. This is most commonly done by limited their washing to cosmetic cleaning of non-hazardous items. No degreasing, no two-step chemicals, no Aluminum Brightening, and no battery washing as these items may cause your heavy metals to exceed sanitary sewer limits and cause your wash water to test hazardous.
- What follows are the most popular Environmental Mobile Power Wash Options as they are now being enforced and practiced today.
- STORM WATER PERMITS
The portion of the Clean Water Act that is effecting Mobile Power Washing the most is the National Pollution Discharge Elimination Systems (NPDES) Permits required by the EPA for Storm Water runoff. NPDES Permits are basically storm water management plans. The NPDES Permits effecting Mobile Power Washing are the ones required for States, Cities, and Fleet Owners. These permits require the cleaning up of Rain Water and Snow Water runoff into our lakes and streams. This includes the elimination of pollution from washing operations entering our lakes and streams carried by Storm Water runoff.
- Phase I of the EPAs NPDES Permits for cities over 250,000 population were due November 16, 1992, and for cities over 100,000 population were due May 17, 1993. The NPDES Permits for fleet owners were due October 1, 1993. These permits included procedures of how wash water was to be disposed of. The cities were basically given two options to come into compliance with their discharge limits. They can collect and treat all of their sanitary and storm water or they could go to the source of the pollution and control the discharge, like Mobile Power Washing. This is the most popular option and it means that wash water will have to be discharged to sanitary sewer. A major part of the Phase I permits is public education for these cities. The most visible part of the Public Education Program is Environmental Inserts and Advertising Space in local News Papers giving Home Owners hints for better Environmental Management. This literature almost always includes phone numbers of the local Environmental Regulators.
- There are approximately 200 Phase I cities over 100,000 population, they are: Abilene, TX; Akron, OH; Allentown, PA; Amarillo, TX; Anaheim, CA; Ann Arbor, MI; Anchorage, AK; Arlington, TX; Arlington VA; Aurora, CO; Aurora, IL; Austin, TX; Baltimore, MD; Bakersfield, CA; Baton Rouge, LA; Beaumont, TX; Berkeley, CA; Birmingham, AL; Boise City, ID; Boston, MA; Bridgeport, CT; Brownsville, TX; Buffalo, NY; Cedar Rapids, IA; Chandler, AZ; Chattanooga, TN; Chesapeake, VA; Chicago, IL; Chula Vista, CA; Cincinnati, OH; Cleveland, OH; Colorado Springs, CO; Columbus, GA; Columbus, OH; Concord, CA; Corpus Christi, TX; Dallas, TX; Davidson, TN; Dayton, OH; Denver, CO; Des Moines, IA; Detroit, MI; Durham, NC; Elizabeth, NJ; El Monte, CA; El Paso, TX; Erie, PA; Eugene, OR; Evansville, IN; Fayette, KY; Flint, MI; Fort Lauderdale, FL; Fort Wayne, IN; Fort Worth, TX; Fremont, CA; Fresno, CA; Fullerton, CA; Garden Grove, CA; Garland, TX; Gary, IN; Glendale, AZ; Glendale, CA; Grand Prairie, TX; Grand Rapids, IA; Green Bay, WI; Greensboro, NC; Hampton, VA; Hartford, CT; Hayward, CA; Hialeah, FL; Hollywood, FL; Honolulu, HI; Houston, TX; Huntington Beach, CA; Huntsville, AL; Indianapolis, IN; Inglewood, CA; Irvine, CA; Irving, TX; Jackson, MS; Jacksonville, FL; Jersey City, NJ; Kansas City, KS; Kansas City, MO; Knoxville, TN; Lancaster, CA; Laredo, TX; Lakewood, CO; Lansing, MI; Las Vegas, NV; Lexington, KY; Little Rock, AR; Livonia, MI; Lubbock, TX; Lincoln, NE; Long Beach, CA; Los Angeles, CA; Louisville, KY; Macon, GA; Madison, WI; Miami, FL; Memphis, TN; Mesa, AZ; Mesdo, CA; Mesquite, TX; Milwaukee, WI; Minneapolis, MN; Mobile, AL; Montgomery, AL; Moreno, Valley, CA; Nashville, TN; New Haven, CT; New Orleans, LA; New York, NY; Newark, NJ; Newport News, VA; Norfolk, VA; Oakland, CA; Oceanside, CA; Oklahoma City, OK; Omaha, NE; Ontario, CA; Orlando, FL; Overland Park, KS; Oxnard, CA; Pasadena, CA; Pasadena, TX; Paterson, NJ; Peoria, IL; Phildelphia, PA; Phoenix, AZ; Pittsburg, PA; Plano, TX; Pomona, CA; Portland, OR; Portsmouth, VA; Providence, RI; Raleigh, NC; Rancho Cucamonga,CA; Reno, NV; Rochester, NY; Rockford, IL; Richmond, VA; Riverside, CA; Sacramento, CA; Salem, OR; Salinas, CA; Salt Lake City, UT; San Antonio, TX; Santa Clarita, CA; San Diego, CA; San Francisco, CA; San Jose, CA; Santa Ana, CA; Santa Rosa, CA; Savannah, GA; Scottstdale, AZ; Seattle, WA; Shreveport, LA; Simi Valley, CA; Sioux Falls, SD; South Bend, IN; Spokane, WA; Springfield, IL; Springfield, MA; Springfield, MO; St. Paul, MN; St. Petersburg, FL; Stamford, CT; Stockton, CA; Sterling Heights, MI; Sunnyvale, CA; Syracuse, NY; Tacoma, WA; Tallahassee, FL; Tampa, FL; Tempe, AZ; Thousand Oaks, CA; Toledo, OH; Topeka, KS; Torrance, CA; Tulsa, OK; Virginia Beach, VA; Waco, TX; Warren, MI; Washington, DC; Waterbury, CT; Wichita, KS; Winston-Salem, NC; Worcester, MA; and Yonkers, NY.
- Phase II of the EPAs NPDES Permits for cities under 100,000 has been extended by the EPA until August 2, 2001. Therefore, in cities under 100,000 population the main environmental pressure will be from your customers with Environmental Departments.
The American Trucking Association had their first ever National Conference on Environmental Vehicle Washing April 6, & 7, 1995 in Fort Lauderdale, Florida. Powerwash.com of Fort Worth was a sponsor of that seminar. There were over 180 people in attendance, and some of the companies represented were: Adams Motor Express, Allwaste Container Services, Anderson Concrete Corporation, Alterman Transport Lines, Blue Shores Distributing, Buffalo Fuel Corporation, Catwba Rental Company, City of Delray Beach, Commercial Carrier Corporation, Contractors Chemical Corporation, Dana Container, Deans Foods Company, DSI Transport, Federal Express, Florida Power and Light, Florida Transport Company, Stoops Freightliner, Gator Leasing, General Parcel Service, Gold Kist Incorporated, R. O. Harrell Incorporated, Hogan Motor Leasing, Iowa 80 Group, Keen Companies, Kenan Transport Company, Landstar Poole Incorporated, R. L. Leek Industries, Liquid Carbonic Industries, Martin Brower, Matlack Incorporated, Mitchell Transport, National Auto/Truck Stops, National Automobile Dealers Association, Oakwood Service LTD, Paccar Leasing Corporation, Pals Express, Penske Truck Leasing, Pepsi Cola, Pitt Ohio Express, ProSource Distribution, Roadway Package Systems, Rollins Truck Leasing, Ruan Leasing Corporation, Ryder Truck Rental, Shelton Trucking Service, Southeastern Freight Lines, Super Transport Incorporated, SuperValu, Texas Instruments, Texo Corporation, Transport International Pool, Union Pacific Properties, United Parcel Service, UPS Truck Leasing, US Army Reserve Command, US Postal Service, Victory Express, Watkins Motor Lines, and Yellow Freight Systems. All of these companies are in the process of implementing Environmental Correct Vehicle Washing Procedures. And companies that are utilizing the services of Contract Cleaners are going to require that Environmental Correct Vehicle Washing Procedures be used! What happened in Fort Worth, Texas is typical across the Nation. In 1993 the Department of Environmental Management tested over 560 storm water sites within the city of Fort Worth. Detergent was discovered in over 50% of these sites making detergent the most encountered pollutant in the City. It was determined that cosmetic cleaning was a significant source of these detergents. The EPA is giving the City of Fort Worth five (5) years starting in 1996 to show a decrease in the pollutants at the 560 sites. If the city does not clean up its storm water the EPA may require a treatment plant to be constructed at the cost of several hundred million dollars similar to the Sewer Treatment Plant to treat all of the storm water. Therefore, starting in January 2, 1996 all of Mobile Power Wash Operators will have to be license in the City of Fort Worth. This license will include a permit to discharge to the sanitary Sewer for cosmetic cleaning of un-concentrated wash water.
- NO OFF PROPERTY DISCHARGE
- No off Property Discharge is the most popular Environmental Power Washing Option today. No problems exists if no wash water leaves the property where the washing is accomplished. However, there are some potential risks with this procedure. They are: 1) when the property is sold a soil test may be required and remediation can be extremely expensive, or 2) the ground water may be contaminated and require remediation, this hazard is very high in areas where the ground water is close to the surface as in Miami, Florida.
- A warning is normally given on the first offense to the either the Contract Cleaner or the Customer. The 2nd or 3rd offense is normally a fine of $800.00 to $1,200.00. Some cities will fine the companies while other cities will fine the employees. A fine is not normally given on the first offense because most cities are striving for voluntary compliance.
- Some areas are allowing 1 to 8 vehicles to be washed on grassy areas and depend on nature to remediate the wash water.
Uncontrolled vehicle washing is presently being permitted in Arizona and Iowa. This is for cosmetic washing with biodegradable detergents. Contact Representative for Arizona is Bill Engstrom at 602-207-4696 and for Iowa is Steve Williams at 515-281-8884. While these two states may have decided not to regulate Mobile Power Washing at this time the individual Cities may in fact do so!
- SEWER TYPE
- There are basically three types of sewers, they are: Sanitary, Storm, and Combined. Most cities have a Sanitary and a Storm Sewer System. The Sanitary Sewer System is what your home sewer is hooked up to. This system of pipes goes to the sewer treatment plant or Public Owned Treatment Works (POTW). At the POTW the sewage is treated and discharged to lakes or streams. This is where your wash water needs to go for treatment before being discharged to lakes and streams.
The Storm Sewer is where the rain water goes in to gutters along the streets and roads. This water is generally discharged directly to lakes and streams without treatment. Because this water is not remediated before discharge into the environment you should not discharge your wash water to a storm sewer.
- Some cities have a combined sewer system where the sanitary and storm sewer are one system and all of the sewage and storm water are treated at the POTW. In these areas the wash water can be discharged to storm sewer. You will need to call the Sewer Department in each area you are washing in to determine which system you are discharging to.
- Most outside drains are storm sewers and most inside drains are sanitary sewer drains but not always. Be sure to know which is which. If your customer does not know call the Sanitary Sewer Department you are hooked to and they will come out and determine which sewer system each drain is hooked to. In many areas this service is free.
- The capacity and capability of POTWS vary greatly and so do their discharge limits. Discharge limits are determined by many factors including: the size of the body of water they are discharging to such as a lake, river, stream or ocean, what they are discharging, and the amount they are discharging. The larger the body of water the more relaxed are the discharge limits. Because discharge limits and POTW treatment abilities vary the amount of treatment wash water needs before being discharged to sanitary sewer also will vary from POTW to POTW.
- WASH AREA
- The easiest way to go to sanitary sewer is to wash in the customers wash bay or pump your wash water to the wash bay sand trap (Clarifier, Oil/Water Separator, or Restaurant Grease Trap). Some Cities will allow you to wash on a hard surface and pump the wash water to the sand trap. Other cities will not. Their reasoning for this is that they do not feel that the contractor will clean up all of the contaminates after he has finished his washing. And that when it rains all of the contaminates will be washed into the Storm Sewer drain.
- In cities that do not allow washing on a hard surface you will either have to wash on a portable vinyl wash pit or in a designated area that has been bermed up to contain the wash water. Some cities will not allow washing on asphalt as your detergents will attach this surface. Asphalt is basically hydrocarbons and detergents are designed to attack hydrocarbons.
- DISPOSAL OF WASH WATER TO SANITARY SEWER
- Since the discharge limits of POTWS vary so greatly so do the methods of discharge to them. Some POTW will accept wash water without any pretreatment or very little pretreatment, like filtering out the sand. Some POTWS for cosmetic cleaning require only filtering with a 200 micron dirt and sand filter or a carbon filter. What POTWS will want to know is how much wash water you will be discharging and what contaminates will be in the water. A water analysis is generally required, this costs $200 to $400 and some POTW will do this test for free. Some POTWS will accept the wash water without any analysis and require an analysis only if a problem arises.
- A common method for discharging is to sand traps (Clarifier, Coalescer, Oil/Water Separator, or Restaurant Grease Trap) located at Truck Washes, Coin-op Car Washes, and Restaurants. The problem with this is that most cities do not want you taking your wash water from the location where it was generated and disposing of it at another location. This is because if a problem arises there is not a clear path of whose fault it is. Most cities want the water discharged where it was generated in order to cover liability. If there is not a sand trap on location the wash water will probably have to be pretreated before being discharged to a sanitary sewer. Another problem is that there are no rules that clearly define the transportation of wash water from site to site. Sometimes the cities try to classify wash water in the same category as sand trap (grit trap) services. But you are not cleaning out or hauling sand trap contaminates. And wash water almost always tests non-hazardous. Also wash water is considered SPECIAL WASTE by the EPA. This is a different category than sand trap containment. Caution: do not discharge to a sand trap without first getting written permission of the owner of the sand trap.
- A misconception is that biodegradable soaps can be discharged to Storm Sewer. Biodegrading takes time and biodegradable detergents may be quite toxic before they biodegrade. Also there is a problem with what the soap emulsifies, like oils, greases, fats, dirt, pesticides and insecticides And phosphates cause some POTW problems. Phosphates cause a problem because they are good fertilizers and cause algae growth which depletes the oxygen in the water killing the fish. And of course fish kills are very visible with dead fish floating on top of the water which attracts TV cameras which creates the type of publicity you do not need! In some areas phosphate free soaps are required.
- Most POTWS will accept your waste directly. However, this creates an economic problem with Commercial Waste Disposal Facilities. They think you should bring your wash water to them. They see the POTWS as a government organizations competing with them. They already have a professional association representing them, so it comes down to politics and political power. Basically, the Commercial Waste Disposal Facilities will pass your waste on to the POTWS and charge you a fee for this service.
- In some areas Commercial Waste Disposal Facilities are your best economic alternative. Their yellow pages heading is: WASTE REDUCTION, DISPOSAL & RECYCLING SERVICE, INDUSTRIAL. Typical costs for wastewater discharge range from 5 cents to 70 cents per gallon.
- You will need to check with each POTW you are discharging to for their discharge limits. Normally these discharge limits will fall within these ranges: pH--(5 to 6) to (10 to 12); Fats, Oils, and Greases (FOG) or Total Petroleum Hydrocarbons (TPH)--less than (100 to 400) milligrams per liter (mg/l); Total Suspended Solids (TSS)--less than 200 mg\l to no limit; Biochemical Oxygen Demand (BOD)--less than 200 mg/l to no limit; Chemical Oxygen Demand (COD)--less than 450 mg/l to no limit. Heavy Metals Limit Ranges are: Arsenic (As)--less than (0.05 to 0.1) mg/l; Barium (Ba)--less than 5.0 mg/l; Boron (B)--less than 3.0 mg/l; Cadmium (Cd)--less than (0.3 to 0.7) mg/l; Chromium (Cr)--less than 5.0 mg/l; Copper (Cu)--less than (3.0 to 4.5) mg/l; Lead (Pb)--less than (0.1 to 2.9) mg/l; Manganese (Mn)--less than 1.0 mg/l; Mercury (Hg)--less than (0.005 to 0.01) mg/l; Nickel (Ni)--less than (1.0 to 2.0) mg/l; Selenium (Se)--less than 0.4 mg/l; Silver (Ag)--less than (0.1 to 1.0) mg/l; and Zinc (Zn)--less than 5.0 mg/l. If your wash water is outside the sanitary sewer discharge limits, you may still be able to discharge to the sanitary sewer but have to pay a surcharge.
- Some companies have gotten permits to discharge to Leech Fields, Septic Tanks, and Injection Wells. Recently the Health Departments in some areas have been going out and testing these sites. Depending on what is found the companies may be required to stop using these sites or remediate the discharge areas. The safest technique is to discharge to Sanitary Sewer wherever possible.
- Most POTWS do not require any pretreatment of the Wash Water when discharging to the Sanitary Sewer through a Truck Wash or Car Wash Bay as these sand traps are designed to for this purpose.
- DISPOSAL OF WASH WATER TO STORM SEWER
- 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. In this document you will see both terms used. As a contract cleaner you will need to be aware of this confusion.). However, there are common exceptions to this rule. They are: washing one or two vehicles on grassy areas occasionally, house washing and building washing because it is rarely done, vehicles washing at residences, and vehicle washing by charities.
- Some Cities are allowing cold water washing with no chemicals (other cities hot water washing with no chemicals where there is no oil and grease, dirt only) to go into the storm sewer if these areas contain no hydrocarbons, pesticides, insecticides, or antifreeze. Hot water washing is considered to be PROCESSED WATER because hot water will emulsify oil and greases. Cold water washing is considered no worse than a rain event. The oil and grease spots should be pre-cleaned with absorbent clay (kitty litter) and disposed of in the dumpster. Leaves, debris, and dirt should be cleaned up before washing so this contamination does not enter the storm sewer. Storm Sewer entrances should be screened to catch leaves and debris and the wash water should pass through an oil absorbent boom or pad to absorb the hydrocarbons. No oil sheen should be present after passing through the oil absorbent filter. No chemicals can be compensated for by using a zero degree rotating nozzle such as a ST-58 Turbo Nozzle or a Rotomax Zero Degree Rotating Nozzle. Typical washing examples are: Vehicles on Dealer Lots (dust only), sidewalks, shopping malls, parking lots, buildings, and homes.
- Some cities will allow building washing with acid cleaners if the acid is neutralized before entering the storm sewer. Typical neutralization is with baking soda (sodium bicarbonate), soda ash (sodium carbonate), or alkaline detergent wash such as R109, or DNB 1430 instead of a clear water rinse. In other cities the cleaning is done with cold water , no chemicals, and rotating zero degree nozzles such as the ST-58 Turbo Nozzle or the Rotomax.
- RECYCLE WASH TECHNIQUES
Recycle Units clean the water only enough so that the water is suitable for washing but not rinsing. Recycle Units that clean the water to rinse water quality are too expensive for contract cleaners. Therefore, rinsing will have to be done with fresh water. Normally recycle units do not remove detergents, total dissolved solids, or heavy metals. This means that your detergent usage will decrease, but it also means that if you recycle the wash water long enough it will test hazardous and have to be disposed of at a Hazardous Waste Facility and you may have to obtain a Hazardous Waste Generator Permit. The trick is to recycle the wash water only long enough that it is still within the discharge limits of the sanitary sewer and before it tests hazardous. A popular technique of many Environmental Power Wash Contractors is to limit their business to cosmetic cleaning of nonhazardous items and not to do heavy degreasing, acid or two step washing, heavy brushing, or aluminum brightening as these activities cause problems with Heavy Metals, and Hydrocarbons. For cosmetic cleaning of nonhazardous items you should be able to recycle for one or two days and still stay under sanitary sewer discharge limits with filtration and absorption technologies. Examples are: Vacuum Sludge Filtering Systems, and the Recycle 16.
- Evaporation and drag off for fleet washing are normally 30 to 50 percent. This loss is made up with rinse water. Under good water management practices your rinse water will not exceed your loss due to evaporation and drag off. Water loss due to evaporation in doing flat work is related to temperature and how far the water travels over a hot concrete surface. Water loss will normally range from 20 to 60 percent.
- As previously stated washing will have to be done with recycled water with detergent in it because the Recycle Systems do not remove the detergents.. The longer you use the wash water the harder it is to rinse off even though you are using a fresh water rinse. Therefore it is common for Contract Cleaners to use their recycle units as pretreatment units for direct Sanitary Sewer discharge. Another technique that has caused some problems is pre-spraying the equipment with a heavy detergent then using a fresh water wash. This technique over flows a recycle system with water. This procedure will only work if you are using the Recycle Unit as a Pretreatment Unit for direct discharge to the Sanitary Sewer. This also applies for Heavy Degreasing, Two Step Chemical Washing, and Aluminum Brightening.
- SLUDGE DISPOSAL
- 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 shovel is an inexpensive method of picking up dirt and debris. The lower the technology to collect the sludge the less expensive it is. The cheapest place to collect dirt, sand and sludge is right off the wash pad.
- Sludge from non-hazardous washing operations falls under the broad heading of SPECIAL WASTE, and will have to be handled according to federal, state, and local regulations. These options should generally meet these requirements:
- A. Put in the customers sand trap if available. You should get permission to follow this procedure.
- B. Let the dirt, sand , and sludge dry and leave for the customer to put in his dumpster. Presently landfills cannot accept liquid waste. In Texas you can put 220 pounds of dry sludge in your dumpster per month. 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.
- C. Put the sludge in a 55 gallon drum and have a licensed sand trap service haul the sludge to a proper disposal site.
- D. 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.
Note: You can find Sand Trap, Grit Trap and Grease Trap Services under GREASE TRAP and MUD TRAP SERVICE in the yellow pages.
- HYDROCARBONS DISPOSAL (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 disposed of your used-oil in the aforementioned manner. It should be noted that the states of California, Arizona, Massachusetts, Minnesota, Missouri, New Jersey, New York, Rhode Island, South Carolina and Vermont regulate used oil as a hazardous waste. Also some states designate used oil as a special waste and have rules more stringent than those of the EPA, these are Arizona, Illinois, Maine, Michigan, Minnesota, Washington, Wisconsin, and Wyoming. Also some counties have even more rules concerning used oils.
- 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.
- In Texas waste oil spills of 9 gallons or more will require reporting to the Texas Natural Resources Conservation Commission (TNRCC). Therefore, leave the hydrocarbons with your customer or only transport small quantities.
- 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.
- HAZARDOUS CLASSIFICATION
- You may be challenged as to whether the sludge or wash water generated is hazardous. Several contractors and American Trucking Association Members have had to have this test done. The test required is the TCLP test. To date all tests that Powerwash.com of Fort Worth has known about have resulted in non-hazardous classification of wash water and waste for cosmetic washing.
- The transportation of 1000 pounds of hazardous chemicals that some contract cleaners use will require a commercial license with a hazardous endorsement. Check with your DOT office to see specifically how these rules will affect you in your location.
- Several companies doing cosmetic washing have had a problem with zinc causing hazardous classification. The zinc was not from their washing operation but from the city inlet supply. Old galvanize pipes were contaminating the water!
- Remember, you are in the Environmental Business and this may cause you to be inspected closer than normal. Old batteries, old tires, or used oil may cause you to be classified as storing hazardous waste. Be tidy, it best to keep your property cleaned up.
- WASTE OWNERSHIP
Ownership of any Hazardous Waste and Special Waste that is regulated by state or local agency is the generator of that waste. Presently this ownership cannot be transferred under any circumstances. Therefore, your customer owns the waste from your washing operations and he is responsible for the waste forever. Your customer is still responsible for his waste even after a licensed waste hauler picks it up. The waste generator is responsible from cradle to grave under present law. This means that if the licensed hauler illegally disposes of his waste he maybe liable for clean up! Presently the only exception to this is in the state of Oregon where ownership can be designated as either the Contract Cleaner or the Customer.
- WASH WATER PROCESSING EQUIPMENT
There are five distinct categories of Wash Water handling equipment, they are:
- A. Wash Water Haulers (WWH) This equipment simply picks up the wash water and hauls it to a proper disposal site. Normally this consists of a sump pump or wet/dry vacuum with a sump pump which pumps the water to a 500 to 2000 gallon holding tank for transportation to the disposal site.
- B. Direct Discharge Units (DDU) These units are sump pumps or wet/dry vacuums with a sump pump which pumps the wash water directly to sanitary sewer. Little or no pretreatment is done. Most systems will filter out the leaves and debris before discharge to sanitary sewer. Examples are: WPSP-25 wash pit sump pump, Wet/Dry Vac with a Sump Pump, and the VSF-8 Vacuum Sludge Filtering Systems.
- C. Pretreatment Units (PU) These units are designed to pre-treat your wash water then discharge it to sanitary sewer. Examples are: VSF-8 Vacuum Sludge Filtering Systems, Recycle 8A, Recycle 16, and the Model 2000 Recycle System.
- D. Limited Recycle Units (LRU) These units are designed to recycle your wash water for a limited amount of time before discharging to sanitary sewer. Generally they recycle your wash water from one to two days. The longer the recycle time the more expensive the equipment. The technique is to limit the recycle time so that the wash water is below the discharge limits of the Sanitary Sewer. For cosmetic cleaning this is usually 8 to 16 hours of recycle washing. Examples are: Recycle 8A, Recycle 16, Model 2000, and The Recycle 1, 2, 3 Mobile Wash Rigs.
- E. Total Recycling Units (TRU) True Total Recycling Units, that produces rinse water quality water are too expensive for normal mobile power wash operations. These units are commercially profitable only in unusual circumstances where the increased cost of operation can be passed along to the customer.
- F. Water Control Devices (WCD) Water control devices are items that pick up or control the flow of wash water so that wash water can be properly disposed of, they are:
- Sump pumps
- wet/dry vacuums with internal sump pumps
- Vacuum sludge filtering systems
- Vacuum booms
- Portable dams
- drain covers
- Portable Vinyl Wash Pits
- Oil Absorbent Pillows, Booms and Pads
- Storm Sewer Drain Screens
14. ;WHAT YOUR ENVIRONMENTAL POWER WASH CUSTOMER WILL REQUIRE
- A. Letter of approval of your Environmental Power Wash Procedures
- B Letter of Acceptance for your Environmental Wash Waste
- Depending upon the sophistication of your customer, generally the larger the customer the more knowledgeable they are, they will require both a letter of approval of both your wash procedures and a letter of acceptance for your waste. In most large cities these letters can be obtained from the Storm Water Department and the Sanitary Sewer Department. A lot of municipalities have not yet issued this type of approval. But as more customers are requiring these documents the municipalities are doing them. It will be easier if you use one of our samples showing them what some other city has done. Remember, if you are the first one to approach the municipality you will have a chance to set the standards in your area.
- 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. Powerwash.com has helped many Contract Cleaners in almost every state implement this process.
- Some fleets have reverted back to unrestricted washing since the Republicans have come to power. However, this has happened only on an isolated basis. For the most part enforcement is increasing in all cities over 100,000 population because their NPDES Permits require it.
15. RISK MANAGEMENT
- If the Clean Water Act is enforced as it is written home owners will no longer be able to wash their automobiles in front of their homes and discharge their wash water to storm sewer. Of course the public is not ready to pay this price to clean up the environment. However, the coin-op car wash operators are pushing for this very thing to happen because it will increase their business (revenue stream). They have been successful in several areas in stopping the Boy Scouts and Girl Scouts from their fund raising car wash activities where the wash water was disposed of to the storm sewer.
As you travel the nations Interstate Highways its obvious that the enforced speed limit is not 55 MPH. The most enforced speed limit is 70 MPH. Rarely is a traffic ticket given for under 70 MPH. But if you requested authorization to drive 68 MPH you cannot get it. So we have a written speed limit and an enforced speed limit. If you drive 68 MPH your risk of receiving a ticket is minimal and a risk that most people are willing to take. Why is this important to the Environmentally Correct Mobile Power Wash Operator? Because a lot of what you will be doing will be risk management. The exact Mobile Power Wash Procedures that satisfy the Clean Water Act are not clearly defined and the procedures fall between the cracks of existing regulations. You can find as many interpretations of the regulations as you can find environmental regulators.
- Presently a large number of Mobile Power Wash Operators have verbal approval for: 1) Disposing of wash water at: Truck Washes, Coin-op Car Washes, Their own sand traps, and POTWS; 2) Disposing of the sludge at: the customers dumpster, in the customers sand trap, your own sand trap; 3) washing on a concrete parking lot; and 4) pre-treating your wash water and disposing it in the clean out trap. This verbal approval is good until someone complains such as a Coin-op Carwash Operator, Sand trap Service, Commercial Waste Disposal facility, or a competitor. The reason they are complaining is because you are effecting their revenue stream. Again it is politics and political power. The Coin-op Carwash Operators and Sand trap Services have Trade Groups representing them.
o;;; What happens if you are cited for improper washing procedures and your competitor is not? Normally this puts you at a competitive disadvantage with customers who are not environmentally conscious. These customers will probably go with the lowest bid. Environmentally correct washing is more expensive and puts you at a competitive disadvantage. Many Mobile Power Wash Contractors have been faced with this problem. Now they are in a position of not being able to provide for their families because of an uneven playing field. This is not an unusual situation and it is happening over and over again as Environmentally Correct Washing Procedures are being implemented. Again you are effecting the revenue stream. Because of this economic pressure it not unusual for competitors to turn each other in for improper washing procedures. Taking photographs, videotaping, and calling regulating authorities about improper washing procedures by a competitor or customer is not unusual. This will probably continue as long as there is such a wide variation in interpretation and implementation of Environmental Washing Procedures to satisfy the Clean Water Act. ;
16. OPPORTUNITY SPEAKS, ARE YOU LISTENING? This State of Confusion spells opportunity for many contractors. Never again will it be so easy to influence how the Clean Water Act will be implemented in your area. Those contractors who are the first ones in their service areas to offer and promote Environmental Power Washing are reaping the rewards of their efforts. Environmental Power Washing is the growth area for Power Washing Today. Just one example is the Post Office. In Fall of 1994 they abruptly stopped all washing on their property that was not Environmentally Correct. More and more customers will take this position as they become aware that there is a viable solution to their cleaning problems. Another example is the American Trucking Association which will hold their first national conference on vehicle washing in April of 1995 in Fort Lauderdale, Florida. Opportunity speaks, are you going to listen. Now is the only opportunity you will ever have to make such a big impact on the implementation of Environmental Washing Procedures with so little effort. Timing is everything and the time is now!!!!
1997 Mobile Pressure Power Washing Environmental Update By: Robert M. Hinderliter Powerwash.com October 10, 1997 Environmental Power Washing is not just Mobile Recycle Pressure Washing on a Portable Vinyl Wash Pit. These are but two elements of Environmental Power Washing just like "a", "b", "c" are letters of the alphabet. Simply stated Environmental Power Washing is Pressure Washing with "No Off Property Discharge" and discharging your wash water to the Sanitary Sewer. This definition will fit most pressure washing operations that are being done within Environmental Guidelines. It should be noted that "No off property discharge" means above and below ground and discharge to Sanitary Sewer means any place that is properly approved to receive your wash water. The most common discharge location is Municipal Sanitary Sewer Systems (or POTW: Public Owned Treatment Works). The preferred entry point is a Sand Trap, or a Grease Trap. Many municipalities are also allowing other points of entry such as slop sinks, mop sinks, sanitary sewer clean outs, commodes, inside floor drains, etc. 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 tool box 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 Contractor to have more than 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. Recycle Systems do not remove the Total Dissolved Solids, Heavy Metals, Detergents, Herbicides, Insecticides, or Pesticides. Hence the longer you wash with Recycled Water the harder it is to get something clean and you have to rinse with fresh water. Therefore washing with Recycled Water needs to be the option of last resort. The same is true for washing on a portable vinyl wash pit. Articles have to be moved to the wash pit. Often times washing items in place then capturing the wash water is a less expensive option. Many municipalities will now accept wash water with minimal pretreatment. This is because the impact of the wash water from Contract Cleaners on the on the POTW (Sewer Treatment Plant) is insignificant. It should be noted that each municipality has the authority to determine what is acceptable within its city limits. The problem is if you are in a Metroplex area where there are many municipalities each one will probably have a difference set of Environmental Pressure Washing Guidelines. What causes this is mostly politics and jealousies among the cities. Common water control devices are (Tools for your tool box): Recycling Systems; Pretreatment or sewer discharge Systems; Limited Recycling Systems; Wash Pits (portable vinyl wash pads), Vacuum Sludge Filtering Systems; Wet-Dry Vacuums, Sump Pumps; Drain Covers; Portable Dams; Vacu-booms; Oil Absorbent Pads, booms, pillows, and tubes; plastic sheeting; Filter Tubs; buckets; pans; and squeegees. You will be designing all sorts of devices to control the water flow. Sometime that will just be using the terrain and natural drainage and catching the water at a low spot to accomplish "no off property discharge". Sometimes this can be as simple as using a wet/dry vacuum and vacuuming up the water before off property discharge. Do not forget about evaporation. A lot of contractors have used evaporation effectively enough that they can wash for several hours and only have to recover less than 55 gallons of wash water. This has been done mostly by letting wash water make long runs across concrete then capturing the water just before it leaves the property. After the washing is finished they clean up the concrete. "No off property discharge" has been achieved and the wash water has been discharged to sanitary sewer. Environmental guidelines have been met. Note that in most locations if the wash water does not exit the property it does not enter the jurisdiction of the Regulating Authorities. For more information see "Environmental Mobile Power Washing, Reality of Enforcement" on the internet at: http://www.powerwash.com/del/delpg5/rept507.html; and "Fort Worth Environmental Regulations for Mobile Pressure Power Wash Cosmetic Cleaning" on the internet at: http://www.powerwash.com/del/delpg5/fterpt.html; Copies can also be ordered from Powerwash.com at 800-433-2113.