City of Fort Worth, May, 2009
Storm Water Quality
Mobile Commercial Cosmetic Cleaning - Background
All Cities Must Have Storm Water Permits
All cities in the United States over 100,000 in population must now have a NPDES Stormwater Permit from the EPA to operate their municipal storm drain systems. One of the key elements of this permit requires the cities to create and enforce an ordinance which bans pollutant discharges to the storm drain. The City of Fort Worth ordinance reads; "A person commits an offense, punishable by a fine, if he introduces or causes to be introduced, any discharge to the storm drain system that is not entirely composed of stormwater." The EPA did grant certain exemptions to this rule in its regulations, and Fort Worth adopted numerous of these in its ordinance as defenses. Some of these defenses include discharges composed of runoff from lawn sprinklers, surfacing groundwater, air conditioner condensation and fire fighting water.
Cold Water Discharges by Power Washers
The Fort Worth ordinance contains a provision that may be used by cosmetic cleaners (power washers) under special circumstances. It states that a discharge or flow of cold water used in cosmetic cleaning that is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance may be discharged to the storm drain as long as the storm drain inlet is screened to catch debris and the discharge passes through an oil absorbent pad or boom. No oil sheen may be present in the discharge after it passes through the pad or boom. The City of Fort Worth Department of Environmental Management recommends screening the storm drain inlet with a 20 mesh or finer screen to catch the debris. Cleaning with hot water (over 110°F) is also allowed under this exemption as long as permission is obtained from Environmental Management prior to starting the job.
Cosmetic cleaners must be very careful if they choose operate under this provision. Even though they may be using water only, with no added detergents, degreasers, etc., they could easily wash off existing pollutants from the surface they are cleaning which could put them in violation of the ordinance.
Fort Worth Must Monitor its Storm Drains
Another element of the EPA Stormwater Permit requires Fort Worth to test selected areas within its storm drain system. Fort Worth has tested over 560 sites. Detergents were discovered in over 50% of these sites making detergents the most frequently encountered pollutant in City storm drains. Repeated field observations of cosmetic cleaning activities showed that a significant amount of detergents were being discharged into the streets and city storm drains. Because the City must show a decrease in the pollutants at the 560 sites over the five years of its NPDES permit, the city enacted specific regulations to limit these types of discharges. The regulations include banning cosmetic cleaning discharges to the storm drain and the implementation of a permit system for commercial mobile power washing activities.
The Cosmetic Cleaning Permit is administered by the Environmental Management Department because it is charged with implementing the city's EPA Stormwater Permit. Detergent in the storm drain is considered a stormwater issue. Other cities may regulate cosmetic cleaning activities through their Public Works Department, Water Department, Water/Stormwater Utility District or other agencies which oversee their EPA Stormwater Permit.
Disposal of Wash Water
The banning of cosmetic cleaning discharges from the storm drain left the operators with two disposal options. The first was to collect their effluent and haul it to an approved treatment facility. The second option was to discharge the effluent to the sanitary sewer, preferably at the job site. The City of Fort Worth chose to require the second option for several reasons. Hauling the waste water to a treatment facility proved too costly for most cosmetic cleaners due to the high per-gallon disposal cost charged by the treatment facilities. Limited testing performed by Environmental Management, in addition to data supplied by the power washing industry, revealed that the average cosmetic cleaning effluent tested below the city's numerical standards (i.e., temperature, pH, oil & grease, metals, etc.) used for approving discharges to the sanitary sewer as long as liquid accumulations of oil, gasoline, grease, etc., were pre-cleaned using an absorbent material.
Because it was determined that pollutant levels in the power wash effluents were low enough for discharge to the sanitary sewer, the Water Department was then concerned with volume. It was estimated that the total volume of wastewater generated by all the cosmetic cleaners operating in Fort Worth on any given day was not likely to exceed 20,000 gallons. The Director of the Fort Worth Water Department deemed this volume "insignificant" when compared to the City's total treatment capacity of 110,000,000 gal/per day.
The Water Department's final concern involved how the cosmetic cleaner was going to access the sanitary sewer. Everyone was in agreement that the waste water belonged to the property owner, not the cosmetic cleaner, so the waste water should be discharged on-site if possible. The ideal discharge point would be into a sand or grit trap such as those found in car wash bays. Unfortunately, few sites contain such facilities so the discharge options revert to sinks, toilets, floor drains and clean-out stubs. It does not matter which of these conveyances the cosmetic cleaner uses as long as the discharge does not contain grit, grease or other substances which could possibly clog the pipe, and the discharge meets the numerical standards discussed above.
Environmental Management recommends discharging through a 400 micron filter to remove the grit and sludge. It is up to the property owner to decide which conveyance to discharge into as they own the plumbing system located within their property lines and are ultimately responsible for what is in their system. It should also be noted that discharges into manholes are 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. Waste water that is pre-treated before discharge to the sanitary sewer is, by city definition, a process water and thereby subject to the rules and regulations of the Water Department's Division of Industrial Waste. Cosmetic Cleaners that utilize wash water recycling units fit into this "process water" category and must test their effluent at least once annually. The results of the tests must be sent to the Division of Industrial Waste to determine compliance with the numerical standards for discharge to the sanitary sewer.
The EPA requires that the Division of Industrial Waste have the ability to take samples from the effluent of all process waters, so cosmetic cleaners using wash water recycling units must supply a map of all of the discharge points they use as a part of their Cosmetic Cleaning Permit.