Increasingly complex legislation
for discharging wash-water into storm drains means pressure washer
operators and cleaning contractors are now facing new challenges in
performing what used to be routine washing tasks.
The problem: Storm
drains discharge directly into lakes, rivers, or the sea without any
treatment whatsoever and thus pose an environmental threat should polluted
water (wash water) enter the system. Strict Federal, State and Local
ordinances are being enacted which forbid anything but precipitation
water (rain and snow) from entering storm sewers and also provide
heavy penalties to those found violating these rules.
Pressure washer
operators and, for that matter, anyone generating wash/waste water, are
becoming the object of intense municipal scrutiny as these new regulations
are enforced with more regularity.
Some Typical Municipal Regulations
Regulatory laws
identify Storm Water Conveyance Systems as roads, streets,
gutters or any other means of carrying storm-water into lakes, rivers, or
the sea. With very few exceptions, it has become unlawful to discharge any
type of non-storm water into the Storm Water Conveyance
System.
Depending on the
locality, some of the exceptions are: individuals washing their cars;
excess lawn watering which flows into streets and, those water flows
resulting from fire-fighting. Pressure-washing operations are definitely
not among the exceptions. Moreover, we are aware of pressure washer
operators being cited and fined merely for leaving small residual traces of
water on the ground with none of it flowing away anywhere!
While the above
incident is an example of enthusiastic over-interpretation of the
regulations, the implications for the industry are clear. Waste-water must
be controlled and operators must be trained in the basics in order to avoid
fines and bad publicity.
With the concerns of
residents and tourists alike at stake, cities and towns are understandably
nervous at the prospect of polluted water from storm drains adversely
affecting the aesthetics of their river and beach areas.
As an example of
municipal interest in the pressure-washing industry, the city of San Diego, California
has issued a set of laminated instruction cards giving a synopsis of the
regulations. These list and explain regulator defined Best Management
Practices which may help in carrying out the intention of the law.
The cards are free to local owners and operators of commercial
pressure-washing equipment.
Best Management Practices
The San Diego Best Management
Practices for prevention of storm water pollution give a summary
view of what will be required nationwide in the industry in the very near
future. These recommended practices can be summarized as follows:
Planning for
waste-water capture Before starting washing operations, plan how
waste-water will be trapped and collected to avoid entering storm drains
and discharge into streets. Plan what will be done with the collected
water. Arrange water barriers and covers so as to minimize the possibility
of an accidental discharge into storm drains.
Cleaning and washing activities - Use dry methods to pre-clean and remove soil residues to approved
containers if deemed hazardous. Minimize amount of water used during
washing. If hazardous wastes are created during washing operations, avoid mixing
with non-hazardous wash water, to reduce disposal costs.
Wash water
collection and disposal - Recovered wash water may be recycled or otherwise
disposed of in the proper manner. The captured waste-water (if no hazardous
pollutants are present) may usually be discharged onto landscaped areas
with the owners permission and, as long as there is no runoff to
storm drains. However, some beach communities located in regions of steep
cliffs forbid this disposal method. Also, some desert localities prohibit ground
discharge as it might harm native plants.
Otherwise, the
property-owners sewer connection (sink, toilet, etc.) may be used if the
flow rate does not exceed (typically) 20 gpm. Other fairly common
restrictions include a maximum discharge (without a permit) of 2,500
gallons per day from exterior mobile power washing, and 25 gallons per day
(after suitable treatment) from engine washing.
Some communities
require (and charge for) a discharge permit regardless of flow quantity.
Many local codes are available over the internet or by contacting your
local city hall directly.
Enforcement
Beware, most
regulations being enforced now come with teeth. Violations of the
no-discharge rules can be classed as misdemeanors and (in San Diego) are subject to fines of up to
$10,000 per day per violation, up to a maximum of $100,000 for any related
series of violations.
Other localities may
have lesser penalties but fines approaching this magnitude are scary enough
to oblige operators to outfit themselves with the proper equipment and
train their personnel in water recovery as well as washing techniques.
Methods for Complying with Wash-Water Control Laws
While the rules,
regulations, and enforcement codes are available and definite, a real
dilemma for the average operator is how to comply. Commercially available
techniques make up a fairly short list:
Sump pumps
Wet/dry vacuums with internal sump
pump (pump out systems)
Vacuum pumps
Vacuum berms
Portable dams, booms, and berms
Portable plastic wash mats and pits
Drain covers.
Tarps and hand equipment
Sump pumps - For wash-water control use,
these are small units, typically completely submersible, which have the
pump inlet at or near the base, so as to remove standing water. Typical
submersible sump pumps have fractional horsepower motors operating on power
cords and will pump 30-40 gallons per minute at low head.
If a low spot or an
area created by portable dams or booms can be arranged, water can then be
pumped into a separate holding tank or septic system (toilet, sink etc.).
This type of system is inexpensive though generally not effective and, is
adequate only if septic systems are close by.
Wet/dry vacuum with internal sump
pump Vacuums of this type are especially useful for
sweeping up standing water from floors, walks etc, and are typically much
more rugged than the shop-vacs sold to homeowners.
In addition to having
more powerful motors for applying suction (up to 2 hp, typically), the
vacuum tank includes a sump pump to remove and discharge accumulated water
to the sanitary sewer (or other approved discharge area). The maximum
suction lift obtainable with these vacuums however, is quite low for
constant working conditions and pump out capabilities are limited, at best.
Vacuum pumps - Positive-displacement
Roots-blower type vacuum pumps are a giant step up in power and capacity
and, are advantageous in that they have the additional power to screen and
filter the recovered water as it is picked up, thus reducing the need for
additional equipment. The higher power also permits multiples of 50 ft hose
lengths to the water recovery site.
Engine-driven versions
are also independent of possibly limited power supplies required by
electrically powered systems. Typical units feature a 5 to 7.5 hp engine driving
the blower and are rated at a minimum of 12 mercury suction at 200
cfm air-water flow. Larger capacity units are also available. Units
complete with vacuum berm, screen and filter tank with automatic pump-out,
hoses, etc, rated at waste-water recoveries up to 40 gpm, are most
appropriate for professional cleaning contractors.
Vacuum berms - These are flexible dams of
around 4-6 inches height, which can be arranged to intercept ground water
resulting from washing operations. Hooked to a vacuum system, they employ
rows of holes at the ground surface to suck up the water which has been
corralled by the berm.
The best designs trap
and collect every bit of the water flowing against the berm; a dry surface
on the lee side of the berm is common. Available in various lengths, these
devices are inexpensive, very effective and the most practical method for
the professional cleaner.
Portable dams - These are 5-6 inch diameter
soft plastic tubes of various lengths (typically 4-5 ft.) which are then
filled with a heavy substance, either sand, a mixture of sand and styrofoam
pellets, or water, and arranged to block, corral, or deflect running waste
water into collection areas.
The weight and
flexibility of these plastic tubes form a tight seal against the ground
surface, thus controlling runoff. These tools are inexpensive,
indispensable and two or more should be on every contractors work
truck.
Portable
plastic wash mats and pits - These are used principally to control waste-water
when washing vehicles, although many other applications come to mind. They
consist of heavy plastic watertight sheeting arranged with foam or
inflatable berms all around, thus forming a catchments area.
Typically, vehicles are
driven onto the wash mat with double berms at each end to reduce the
likelihood of water loss upon entering or leaving the pit. After vehicles
are washed, the waste water on the pit is removed with a sump pump or
vacuum.
For the general
pressure-washing contractor, versions are available to catch water from interior
or exterior wall washing, for example. Prices vary according to size and
function.
Drain covers - These are plastic sheeting
arrangements designed to cover storm-drain openings as a precaution against
failure of other waste-water collection devices.
Several versions are
available. For horizontal openings, a small version of the
wash-mat can be filled with water; the weight thus seals off
the area surrounding the storm-sewer grate. A version containing magnetic
material can be used where steel grating is present.
However, it should be
stressed that water approaching a storm drain is already in the
Storm Water Conveyance System so drain covers are a
precautionary measure or last resort.
Tarps and hand
equipment
Traditional, but not to be forgotten equipment includes mops, buckets,
and grease absorbers for use before washing.
Complete Water
Recycling
Several companies offer
complete recycling systems which reuse water originating from power
washing. Basically these systems consist of a portable storage tank of 50
gallons or so, which feeds the high-pressure washer.
Waste water is then
diverted by suitable dams or booms to the entrance of a vacuum berm. The
waste water is then conveyed by vacuum pumps to a tank or series of tanks
where it is then screened and filtered. The resulting fluid is then pumped
out of the final tank and, through more filters, by a sump pump in the tank
to the storage tank for reuse. The scheme is certainly environmentally
correct, and may be essential in locations where water must be hauled to
the site. A complete recycling is thus achieved.
Two considerations
involved here are perhaps minor: due to evaporation, not all the water used
in washing can be recovered, and allowance for this loss, which may amount
to 20% or so, may increase the volume of storage tank required. Another
factor seems to be that the recycled water gradually looses quality in
spite of filtering, due to bacterial contamination.
Training,
Certification, and Documentation
Since, in most states,
the property owner is also the legal owner of the waste water produced at
his property, actions to prevent citation for violation of discharge rules
by the cleaning contractor or power washing operator should yield
significant competitive advantages.
These actions
would include not only the ownership and use of proper equipment, but also
training employees in how best to use the equipment to meet environmental
legal requirements. This training should be passed on to all front-line
personnel in a structured way, complete with hand-outs and documentation.
Commitment
to proper procedures and, awareness of local environmental ordinances
should also impress your local regulatory authorities. In fact, many
municipalities have issued Letters of Approval of Environmental
Power Wash Procedures. Also, a Letter of Acceptance of
Environmental Waste Water for operators discharging only to the
sanitary sewer system is another competitive possibility.
Undeniably,
approval such as this provides a significant competitive advantage for the
contractor who has planned ahead and invested in his future. Certifying
that employees / operators have this training may be just the competitive
edge you need to win that next big contract!
Incidentally,
a comprehensive training course covering the topics of this article will
soon be available from the authors call for information.
The
Opportunities
While the
rules, regulations, and equipment necessary to meet new environmental
standards may seem burdensome, there is no sense trying to Beat City Hall! Operators who gear
up and prepare for these changes will not only avoid painful fines and
stressful regulatory harassment, they will also be the ones who enjoy
the most profitable business opportunities in their respective markets.
As mentioned
earlier, we operate in Southern California
where environmental regulations have become a serious consideration for all
cleaning contractors and pressure washer operators.
In just the
past twelve months, we have seen how these new policies have quickly changed
the competitive landscape in our market. For those business owners who have
accepted the changing laws and adapted, business opportunities appear to be
growing and, more importantly, improving in quality.
Allow
me to explain.
In San Diego, there are a
large number of pressure washer operators. Many are contract cleaners, some
are auto detailers, some are painters and other trades people who use
pressure washing equipment in their daily work.
We serve
most of these businesses through chemical or equipment sales or, by
providing service and repair work for their machinery. Regardless of why
they come to us, we have noticed a trend. Those contractors who are
adapting to new environmental regulations are doing more business than
those who are not.
The reasons
are simple. Those business owners who have adapted to the new laws are
providing better service and better value to their customers. Also, they
are taking the time to explain why it will benefit them to choose
contractors who are compliant with environmental regulations over those who
are not.
Quality
Service Pays
When
property managers and owners are given greater assurances they will not be
involved in legal disputes triggered by untrained or poorly equipped power
washing operations, they are generally more willing to hire those companies
capable of providing these protections over those that are not.
Moreover,
we have noticed that the higher quality customers do not have a
problem paying more for services that are more professionally delivered, environmentally
sensitive and, legally compliant.
In summary, it
is our observation that those contractors who adapt to this new era of
environmental sensitivity can expect to have greater opportunities
available to them than their competitors, enjoy greater respect from their
peers and customers and, not the least of which, get paid better money per
manpower hour.
Undeniably,
professional cleaning is a respectable trade. Rather than lament these new
laws, we feel they will improve the industry as a whole. Less committed
operators will be winnowed out and the industry will be improved and on the
cutting edge of professionalism and quality service.