RECOMMENDED

POLLUTION PREVENTION

PRACTICES

for the

MOBILE POWER WASH INDUSTRY

City of Independence, Missouri

City of Kansas City, Kansas

City of Kansas City, Missouri

City of Olathe, Kansas

Johnson County, Kansas

Little Blue Valley Sanitary Sewer District, Missouri

Greater Kansas City Metropolitan Area

September, 1997


Table of Contents

Preface

Introduction For Each Control Authority

Definitions and Abbreviations

I. Transportation-Related Washing or Detailing

II. Surface Cleaning

III. Food Service and Retailer Cleaning

IV. Prohibited Washwater

Appendices


Preface

These Recommended Pollution Prevention Practices are the product of a series of meetings held in 1996 and 1997, which involved representatives of Water Pollution Control Authorities from within the greater Kansas City Metropolitan area on both sides of the Kansas/ Missouri state line. It is a revision of the Best Management Practices For Power Washers that were distributed in July, 1996. The objective of the group was to prepare a document that would be acceptable to all of the Control Authorities represented in the Kansas City Metro Area and also compatible with applicable regulations enforced by both the Missouri Department of Natural Resources and the Kansas Department of Health & Environment. Similar documents from other metropolitan areas in the United States were reviewed and representatives of the power wash industry and their suppliers consulted to provide an understanding of what the requirements are and how they can be successfully achieved.

The group preparing these Recommended Pollution Prevention Practices was made up of city, county, and sanitary district officials with knowledge and expertise in water pollution control procedures, issues and legislation. It is their hope that the practices will be accepted and followed by power wash operators while in the Kansas City Metropolitan Area. Those principally involved in preparing the original document represent the following water pollution control authorities:

City of Independence, Missouri Water Pollution Control

City of Kansas City, Kansas, Water Pollution Control Division

City of Kansas City, Missouri, Industrial Wastewater Control

City of Olathe, Kansas Department of Utilities

Johnson County (Kansas) Environmental Department

Little Blue Valley (Missouri) Sanitary Sewer District


Introduction

The various Municipalities, Sanitary Districts or County Environmental Divisions in the greater Kansas City Metropolitan Area are responsible for water pollution control and maintenance of Industrial Pretreatment Programs. These programs protect their particular area of the sewage collection and sewage treatment process for citizens of the metro area. Each jurisdiction must have ordinances and policies that will protect the water supply resource for communities downstream. Each has a responsibility to discharge an effluent to the Kansas River, Missouri River, Blue River or other receiving stream that will comply with requirements spelled out in NPDES Permits issued by the state of Kansas or the state of Missouri as required by federal pollution control laws and regulations.

Discharges to the storm sewers come under state regulation. State regulations forbid discharge of wastewaters to ditches, streams, rivers or to the storm sewer without an NPDES Permit. A power washer would have to either obtain such a permit from the state or confine wastewater discharges to sewers that lead to a sewage treatment plant which holds an NPDES permit issued by the state.

These pollution prevention practices outline how wastewater from mobile power wash operations can be assured of coming under a permit issued by the State of Kansas or the State of Missouri to any of six specified jurisdictions in the greater Kansas City metro area.

City ordinances and county codes may vary. Some special requirements may be in place in the different jurisdictions, so this guidance document provides information about each jurisdiction below, including where you can call for answers to questions you may have.

THE CITY OF INDEPENDENCE, MISSOURI:

Water Pollution Control Department
Independence, Missouri 64051-0519
Office of Environmental Compliance

This department regulates the quality of wastewater discharged to the public sanitary sewerage system within the City of Independence, Missouri. It also enforces City code provisions which prohibit discharge of non-storm water to the municipal separate storm sewer system. By following these Pollution Prevention Practices, properly licensed mobile power wash businesses may operate within the City of Independence, Missouri under most circumstances without obtaining site-specific wastewater discharge permits. For circumstances not addressed in this guidance or for additional information, contact the Office of Environmental Compliance at (816) 325-7111.

THE CITY OF KANSAS CITY, KANSAS

Water Pollution Control Department
701 North 7th Street
Kansas City, KS 66101

Power washing services operating in Kansas City, Kansas must be licensed by the City. The required occupation license may be obtained at the License Department on the third floor of City Hall, 701 North 7th Street, Kansas City, Kansas (913) 573-5280. Power wash operations anywhere in Wyandotte County are expected to operate in compliance with the pollution prevention practices described in this guidance document. Power washing wastewaters must pass through one of the local wastewater treatment plants to be in compliance with state and federal regulations. This can only be accomplished by making sure, before beginning operations, that wastewaters will be discharged to the sanitary sewers. For answers to any questions you may have, call the Water Pollution Control Division between 7:00 AM and 4:00 PM at (913) 371-4240.

THE CITY OF KANSAS CITY, MISSOURI

Water Service Department
Industrial Waste Control Division
Oak Tower, Suite 2500
324 East 11th Street
Kansas City, Missouri 64106

The purpose of this document is to inform mobile power wash operators, their clients, and suppliers of the procedures that should be followed when operating in the City of Kansas City, Missouri. These recommended pollution prevention practices briefly describe those procedures associated with the most common types of cleaning . They are designed to promote the proper disposal of wash water (wastewater) produced by mobile power washing.

Note, confusion between a storm sewer inlet that combines with a sanitary sewer and one that discharges directly to the waters of the United States, occurs frequently. To ensure that all wash water (wastewater) goes to the sanitary sewer, a storm water inlet is NOT considered a proper sanitary sewer access point within the City of Kansas City, Missouri.

If you have any questions, or would like to confirm that your method of handling discharge to the sanitary sewer is appropriate, contact the Industrial Waste Control Division at (816)274-2949 or (816)274-1652.

CITY OF OLATHE, KANSAS

Water Department, City Hall
100 West Santa Fe
Olathe, KS 66061

The City of Olathe advises power washers to serve customers in a manner consistent with these Pollution Prevention Practices. If questions arise while serving customers in the Olathe area, powerwash operators or their customers may call 397-5200 for information or additional copies of this document.

JOHNSON COUNTY KANSAS

Environmental Department
11180 Thompson Avenue
Lenexa, KS 66219

The Johnson County Environmental Department operates an industrial pretreatment program covering those facilities subject to the regulations within the Johnson County Unified Wastewater Districts (JCUWD) service area. [Please note that this service area does not cover the entire county.] The industrial pretreatment program is designed to monitor discharges to the sanitary sewers and enforce the Johnson County Code of Regulations for Sanitary Sewer Use, 1992 Edition and state and Federal regulations which limit pollutant discharges from industrial and commercial sources to the sanitary sewers. One source of discharges of concern is the wastewater discharge generated by power wash or water pressure cleaning businesses operating in the JCUWD service area.

These recommended pollution prevention practices briefly describe procedures of the most common types of cleaning and are designed to promote the proper disposal of power wash and water pressure cleaning wastewater to the sanitary sewer, thus minimizing the impact on the storm sewer systems. The purpose of this document is to inform mobile power wash operators, their clients, and suppliers of the recommended procedures power washers should follow when operating in the JCUWD service area. These practices have, as their only purpose, the protection of the environment and the protection of public facilities provided to assure the protection of water quality in Johnson County. Voluntary compliance with these recommended pollution prevention practices is encouraged.

Permission to discharge to the sanitary sewers is required. Contact the Johnson County Environmental Department at 492-0402.

THE LITTLE BLUE VALLEY (MISSOURI) SANITARY DISTRICT

21205 East Old Atherton Road
Independence, MO 64058

The Little Blue Valley Sewer District is comprised of a regional treatment facility serving fifteen communities and one Federal installation in eastern Jackson County, Missouri and a northeastern portion of Cass County, Missouri. Along with wastewater treatment, the District also administers an EPA approved Industrial Pretreatment Program and Hauled Waste Program. Through implementation of these programs, the District ensures unhampered plant operation and provides a needed service to our communities. The District has participated with other metropolitan area pollution control authorities in the development of this document for the Mobil Power Wash Industry. The purpose of this document is to inform the Industry of the best ways to operate without having to obtain a State operating permit. While compliance with these practices is voluntary, the District urges the Industry to follow this guidance.

Additional information may be obtained by contacting the District's Pretreatment Coordinator at (816) 796-7660.

DEFINITIONS AND ABBREVIATIONS

RECOMMENDED POLLUTION PREVENTION PRACTICES - Schedule of activities, prohibitions of practices, maintenance procedures and other management practices to prevent or reduce the discharge of pollutants to the sanitary sewer and to the environment. The practices may also include treatment requirements, operating procedures and procedures to control site runoff, spillage or leaks; and waste disposal.

BOD (denoting Biochemical Oxygen Demand) - A measure of the quantity of oxygen utilized in the biochemical oxidation of organic matter in five days at 20 degrees Celsius, in accordance with U.S. Environmental Protection Agency approved laboratory methods, 40 CFR Part 136. It is expressed in terms of weight and concentration in milligrams per liter (mg/L).

COMMISSARY, PROPERLY EQUIPPED - A catering establishment, restaurant, or any other place in which food, containers, or supplies are kept, handled, prepared, packaged or stored, constructed and operated in compliance with food service sanitation codes.

DISCHARGE or INDIRECT DISCHARGE - The discharge of pollutants into a publicly owned treatment works from any non-domestic source regulated under the Clean Water Act of 1977, 33 U.S.C. Part 1251 et seq., and such other classes of significant waste producers the Control Agency deems appropriate.

HAZARDOUS MATERIAL - A substance or material, including a hazardous substance, which has been determined by the United States Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated in 49 CFR Part 172.

HAZARDOUS WASTE - Hazardous waste as defined in 40 CFR Part 261 and applicable state hazardous waste laws and regulations.

POLLUTANT - Any filter backwash, dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemicals wastes, biological materials, radioactive materials, heat, wrecked or discharged equipment, rock, sand, cellar dirt and nondomestic, domestic, municipal, and agricultural waste discharged into water.

POTW (denoting Publicly Owned Treatment Works) - all facilities for collecting, pumping and treating wastewater that are owned by the municipality or other Control Authority.

PROPER SANITARY SEWER ACCESS POINT - A building drain, building sewer, private sewer clean-out, private sampling manhole or other privately owned sanitary sewer access point. A publicly owned manhole may not be utilized as a Proper Sanitary Sewer Access Point.

SS (denoting Suspended Solids) - The total suspended matter that floats on the surface of, or is in suspension in, water, wastewater, or other liquids, and which is removable by laboratory filtering in accordance with U.S. Environmental Protection Agency approved laboratory methods, 40 CFR Part 136; also referred to as nonfilterable residue.

I. Transportation-Related Washing or Detailing

A. Fleet Washing [Exterior washing to remove mainly dirt with soap]:

  1. Capture the wash water using wash pads, temporary seals over storm sewer, or permanent wash station with no outlet.
  2. Dispose of wash water through proper sanitary sewer access point.
  3. If a permanent wash station is utilized, the wash water may be left for evaporation.
  4. Wash area cleaning protocol are described in Section II.A. of this document.

B. Engine/Equipment Degreasing; Auto/truck drive train cleaning, engine degreasing, airplane cleaning, including landing gear [with or without soap]:

  1. If solvents used are considered hazardous waste under RCRA, then the wash water may be required to be contained and handled as hazardous waste. Disposal to the POTW is subject to review and approval prior to discharge.
  2. If no solvents are used, wash water must be contained and treated, if required, prior to discharging to a proper sanitary sewer access point. Types of treatment may include oil/water separators and coalescers. Contact the Control Authority serving your area for additional information concerning regulations.

C. Acid Cleaning of Unpainted Trucks:

  1. Wash water from acid cleaning must be contained and neutralized. Discharge must be within the pH units as prescribed by the Control Authority.
  2. Dispose of wash water to a proper sanitary sewer access point.

D. Food Related Transportation:

  1. Semi-Trailer Interior Cleaning:

2. Lunch Wagons/Food Carts:

E. Boat Cleaning [with or without soap]

  1. Remove any paint chips by filtering wash water. Dispose of as solid waste, unless waste is considered hazardous waste due to quantity generated and heavy metals content. Contact the appropriate state agency for additional information. The phone numbers are listed in Appendix A and Appendix B.
  2. Dispose of wash water on-site to a proper sanitary sewer access point.

II. Surface Cleaning

The Recommended Pollution Prevention Practices in this section do not apply if there has been an oil or hazardous material release on the site. If a release to the environment has occurred, then notify 911 and the Region 7 Environmental Protection Agency spill line, 913-281-0991(located in Kansas City, Kansas).

A. Sidewalks, Plazas, Driveways, Paved Parking Lots, and Drive-through Window Areas:

  1. Prepare area by sealing all storm drains, then sweep, collect and dispose of debris as a solid waste.
  2. Dry clean all oil spots with absorbent and dispose of as solid waste.
  3. Collect wash water and discharge on-site into a proper sanitary sewer access point. If oil or grit are present, then treat by passing through an oil/water separator. Verify that the oil/water separator is for petroleum type oil and grease prior to usage. Oil and solids are to be disposed of properly. Contact the Control Authority serving your area for assistance.

B. Building Exteriors and Other Structures:

  1. Glass, Steel or Non-Hazardous Painted Structures:
    a. Collect wash water and dispose of on-site to a proper sanitary sewer access point.
    b. If non-hazardous paint chips are present, collect wash water and filter. Dispose of filtered wash water in on-site sanitary sewer. Dispose of paint solids and filters as solid waste.
  2. Wet sand blasting or high pressure washing and cleaning compounds used in graffiti removal or other non-hazardous paint removal: Prepare area so all debris, sand, cleaning compounds, and/or wash water can be removed without discharge to the storm sewer. Collect wash water, remove solids; if required, and dispose of wash water on-site to a proper sewer access point.
  3. Masonry Efflorescence using acid wash to remove mineral deposits on masonry: Prepare area to prevent loss of solid particles or acidic wash water. Collect, remove grit and neutralize the wash water. Dispose of wash water on-site to a proper sewer access point. Dispose of solids as solid waste.

III. Food Service and Retailer Cleaning [with or without soap]:

IV. Prohibited Wash Water:

A. Hazardous Materials Spill/Residual Clean up:

APPENDIX A

Kansas Department of Health and Environment Permitting Procedures for Direct Dischargers

Since October of 1972, with the passage of the Federal Water Pollution Control Act and subsequent revisions, it has been illegal to discharge wastewater without a National Pollutant Discharge Elimination Permit (NPDES) in a location where it may cause pollution to waters of the United States. Any person that discharges wash water needs an NPDES permit. Wash water is considered wastewater regardless of what kind of material is washed off or the biodegradability of the detergents. Single family residences or persons washing items that are for their personal use are exempted. This permit applies to businesses washing their vehicles or structures or businesses that wash for commercial purposes. Mobile washing operations are also subject to these requirements.

An NPDES permit is required for discharges onto a parking lot, regardless of whether water leaves the property (into a drainage ditch, storm sewer, river, etc.) or not. Permits contain limits for various pollutants which usually require some type of treatment of the wash water prior to discharge.

If vehicle washing (or any other type of washing) is done indoors and the spent wash waters are directed into storm sewers or outdoors, then a permit is required.

To be in compliance with state and federal law, operators of vehicle washing operations can comply with one of the following:

A. Apply to the Kansas Department of Health and Environment (KDHE) 180 days prior to proposed discharge to obtain an NPDES permit for every site where they wash vehicles or buildings; to meet the permit limits typically treatment is required. The pollutants listed below have been found in vehicle wash water. The concentrations listed are standard levels which need to be achieved to meet permit limits in most cases. Heavy metals and other pollutants may also need to be included if they are present in the wash water. In some cases, more stringent levels are needed.

PARAMETER CONCENTRATION
Biochemical Oxygen Demand 30 mg/L
Chemical Oxygen Demand 100 mg/L
Total Suspended Solids 30 mg/L
Oil and Grease 10 mg/L
Benzene 5 ug/L
Toluene 1 mg/L
Ethyl Benzene 700 ug/L
Total Xylenes 10 mg/L

B. Wash inside a building or on a paved surface. Collect all wash waster and direct it to the public sanitary sewer, contain, treat or recycle the water on-site. An NPDES permit is not required if a discharge does not occur; however, a state water pollution control permit is required for most evaporative, containment or recycling systems.

C. If a lagoon or underground wastewater storage tank is utilized for vehicle wash water, a double synthetic liner system is required. Contact KDHE for a copy of their requirements for liners and underground industrial wastewater containment tanks:

D. KDHE does not allow industrial wastewater, including vehicle wash water, to be discharge into a septic tank/lateral field wastewater system due to the potential for groundwater contamination.

If you decide to install a lagoon or other type of wastewater treatment/containment facility, the following permitting procedure must be followed in building the facility and obtaining a water pollution control permit:

APPENDIX B

Missouri Department of Natural Resources Technical Bulletin:
Water Pollution Control Permit Requirements For Mobile Wash Businesses

Appendix C

Johnson County Environmental Department Procedures for Special Wastewater Discharge Permitting for Discharge to the Sanitary Sewers

Industrial/commercial facilities discharging process wastewater to the Johnson County Unified Wastewater Districts' sewerage system are subject to the Johnson County Code of Regulations for Sanitary Sewer Use, 1992 Edition and any subsequent revisions. The Johnson County Environmental Department (JCED) administrates the program.

Listed below are the basic steps involved with permitting:

APPENDIX D

LIMITATIONS ON pH IN THE METROPOLITAN KANSAS CITY AREA;

City of Independence, Missouri 5.5- 9.5

City of Kansas City, Kansas 5.5- 10.5

City of Kansas City, Missouri 6.0- 11.0

City of Olathe, Kansas 6.0- 9,0

Johnson county (Kansas) Environmental Department 5.5- 10.5

Little Blue Valley (Missouri) Sanitary Sewer District 5.0- 10.5


Environmental Power Washing Reports and Ordinances


Last Update: November 4, 1997,Robert M. Hinderliter, Webmaster

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