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Date: |
9/15/2005 |
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To: |
Mike Wildgen |
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From: |
Chad Voigt |
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cc: |
Terese Gorman |
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Re: |
EPA stormwater compliance related to car washes and pavement cleaning |
Background - The Kansas Department of Health and Environment issued a permit to the City of Lawrence on September 24, 2004, regulating stormwater discharges from the city. This permit is required by the EPA, through amendments to the federal Clean Water Act.
As a permitted storm sewer operator, we’re required to implement codes and practices to reduce pollution discharged from our storm sewers into the Kansas and Wakarusa Rivers. The program places emphasis on (1) public education about the impacts of stormwater pollution (2) enforcement of local laws to prohibit stormwater pollutants. Additional information is available on our website.
Stormwater runoff in urban areas often includes waste and wastewater from non-stormwater sources. These untreated discharges contribute high levels of pollutants, including heavy metals, toxics, oil, grease, solvents, nutrients, viruses and bacteria to receiving streams. Pollutant levels from these discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife and human health. The EPA provides more information online at www.epa.gov.
Car Washes – Per Federal Code, the City must prohibit non-stormwater discharges to the storm sewer system. The Code also lists exemptions that include “individual residential car washing;” however other EPA documents encourage homeowners to use commercial car wash facilities:
In response to this requirement, many communities have published local information on the topic:
In December 2002 we sent information to potential car wash sponsors: retail stores, banks, schools and fund raiser groups, in anticipation of car wash events. In the last two years we’ve contacted several groups to notify them that a planned car wash would not be allowed. As an alternative, auto dealers and commercial carwash owners have offered their facilities for group fundraiser use.
Pavement Cleaning - Wet cleaning of exterior surfaces is a major source of stormwater pollution. This is particularly true in commercial areas where large impervious surfaces drain directly to storm sewer inlets. Exterior cleaning is a common practice for business owners, and if steps are taken to intercept pollutants, exterior cleaning can reduce pollutants that would otherwise be discharged during rainstorms. The Public Works Department is faced with knowing when and how to regulate wet cleaning activities to meet minimum environmental standards. Our first steps have been to identify what types of cleaning are common and which specific pollutants are priorities.
Wet cleaning equipment ranges from garden hoses to powered high-pressure washers. Pressure washers are typically operated by cleaning contractors; although property owners are now able to purchase inexpensive pressure washing equipment at local retailers. Professional cleaning equipment is more advanced, capable of cutting through paint, coatings and surface buildup.
Pollutants discharged from exterior surfaces include: soil, litter, debris, food waste, landscape debris, pet waste, oil, petroleum products, grease, solvents, detergents, degreasers, acid, paint, toxins and heavy metals. A small container of grease or detergent is considered a higher priority than a pile of landscape debris or soil. A more frequent discharge is considered a higher priority than an isolated infrequent activity. Quantity and frequency are key factors in our response to sources of pollution.
All wet cleaning processes generate wastewater. A stormwater pollution violation occurs when this wastewater carries harmful quantities of pollutants to the storm drainage system. The solution to this problem involves removal of pollutants prior to discharge. This is accomplished by on-site treatment prior to discharge or collection of wastewater for off-site treatment. Pressure washing has the advantage that far less wastewater is generated. A system of high pressure washing and vacuum collection is an efficient way to clean surfaces without generating stormwater pollution. In November 2004 we updated our website to include a guidance document on this topic.
With these factors in mind, we propose the following official enforcement policy:
· A land owner, business owner or tenant may discharge water to the storm drainage system from cleaning of exterior surfaces on their property if the surface to be cleaned does not show harmful quantities of pollutants, the discharge does not contain visible pollutants and the discharge does not lead to visible downstream indicators of pollution such as odor, color or foaming. To achieve this, solid and fluid wastes must be removed prior to washing.
· Professional cleaning contractors may not discharge water from cleaning operations to the storm drainage system. All water generated from cleaning must be collected and transported to an approved point of treatment.
Stricter enforcement may be necessary in later years; however this policy is consistent with current EPA regulations and policies in place in other cities across the U.S.