Attachment_05,_PW_Best_Management_Pract.PDF

Pressure Washing Best Management Practices

1 23 February 2017

Federal and State Regulations

Federal and State regulations prohibit pollutant discharges to water bodies and require that local governments implement stormwater compliance programs that protect water quality. The 325 Civil Engineer Squadron – Environmental Element (325 CES/CEIEC) oversees the bases municipal separate storm sewer system (MS4) permit. This permit is for a publicly-owned conveyance or system of conveyances (i.e., ditches, curbs, catch basins, underground pipes, etc.)

that is designed or used for collecting or conveying stormwater and that discharges to surface waters of the State.

This permit requires the base to:

• Reduce pollutants in stormwater runoff (runoff directly by rainfall) to the maximum extent practicable.

• Effectively prevent non-stormwater discharges to the maximum extent practicable.

Wastewater Discharges Prohibited The MS4 permit regulates discharges into the storm system, which includes the discharge of wastewater from pressure washing/surface cleaning to the storm drain system (including storm drains, roadside ditches, gutters, streets, sidewalks, drainage channels, swales, creeks and streams, or any natural or surface waters.

Discharges to the storm drain system are only allowable when approved by the 325 CES/CEIEC.

Applicability

The information applies to:

• Contractors providing pressure washing/surface cleaning services

• Businesses using pressure washing/surface cleaning equipment in their operations or maintenance (such as cleaning heavy equipment, walkways, parking lots, etc), Wastewater Discharges caused by Pressure Washing

The storm drain system flows directly to creeks, ditches, bayous, bays, culverts, and many other stormwater conveyance systems. Chemicals, dirt, detergents, oil/grease, and heavy metals are common pollutants in wastewater that can harm aquatic life, contaminate our drinking water sources and impair our enjoyment of our recreational waterways.

It is a violation of the MS4 Permit to:

• Discharge wastewater of any kind into the storm drain system, or manage wastewater discharge in a way that results in the potential for pollutant discharges to the storm drain system. This includes potential future pollutant discharges that may occur when it rains or when pollutants

2 23 February 2017 come into contact with irrigation run-off. For example, wastewater that dries on pavement doesn’t create an immediate discharge, but will likely result in residual pollutants being washed in to the storm drain system by a future rain event.

Pressure washing water that isn’t properly managed creates a stormwater pollution problem because:

• Most pressure washing activities are conducted outside,

• Pressure washing wastewater contains pollutants, such as heavy metals, chemicals, or oil and grease, associated with cleaning compounds and/or the objects or surfaces being cleaned.

• Pressure washing wastewater discharged to the storm drain system enters storm drains and flows, without removal of pollutants, directly into sensitive water bodies.

• Pollutants discharged to the storm drain system harm wildlife, fish, and aquatic organisms, contaminate drinking water supplies, and make it unsafe to waterways.

• It is against best management practices and possibly a violation of water quality standards to discharge wastewater to the storm drain system.

Detailed BMP Guidance

Pre-PlanPre-plan

• Coordinate with the 325 CES/CEIEC prior to performing any work.

• Obtain any necessary permits & authorizations for wastewater disposal (such as mobile pressure washer/surface cleaner permit, permit for septage dump station disposal). Fees and work will be paid for by the contractor.

• Identify locations of all storm drains and points where wastewater from your activities could enter the storm drain system.

• Specifically determine how to contain & collect wastewater from each different cleaning activity or work area.

• Identify proper disposal options for the types of wastewater & waste.

• Get necessary permissions to access viable on-site disposal points (Sanitary Sewer).

P Met Pre-Clean (Dry Methods)

• Pre-sweep and use dry spot cleaning methods to pre-clean whenever possible (for example, pre-clean oily deposits with absorbent); don’t allow any pre-cleaning debris/material to enter the storm drain system—remove it before wet-washing.

• Properly characterize pre-cleaning wastes & dispose of them as hazardous waste when necessary (coordinate with the 325 CES/CEIEC).

Use Sound Techniques

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• Block and/or protect storm drains that could potentially be impacted by your activities.

• Locate the property’s high and low spots and determine the appropriate area for wastewater pooling/collection.

• Minimize water usage while cleaning. Utilize water regulating nozzles and/or high pressure delivery systems.

• Use bio-friendly cleaners that are less toxic, or that do not contain hazardous substances, like hydrofluoric acid, muriatic acid, sodium hydroxide, bleach, etc.

• Avoid mixing non-hazardous wastewater with wastewater that contains (or may contain) hazardous materials, hazardous wastes or hazardous pollutants. Doing so may limit your disposal options—and add to your disposal costs—by increasing the total volume of wastewater that may require classification as hazardous waste. Consult the 325 CES/CEIEC to make the appropriate hazardous waste determination.

Collect Wastewater

• Contain and collect wastewater using appropriate containment measures or equipment. If necessary, create temporary wastewater collection area.

• Place an oil absorbent pad on top of collected wastewater to reduce/remove floating oil to reduce the likelihood of that oil being re-deposited on the surface being cleaned. (Dispose of used oily pads as Hazardous Waste)

Properly Dispose of Wastewater/Wastes

• Coordinate with the 325 CES/CEIEC and evaluate collected wastewater/wastes for appropriate means of disposal to either:

1. A Landscaped Area (Uplands)

2. The Sanitary Sewer

3. A Hazardous Waste Treatment/Storage Faculty

4. A permitted liquid waste treatment company.

Analytical sampling maybe required and will be paid for by the contractor.

• Once the wastewater has been collected, it may be necessary to rinse and collect the rinsate wastewater from the area, to avoid leaving behind residue that will be washed into the storm drain at a later time.

• Sweep up any visible solids/residue left after collection/disposal/rinsing to prevent these materials from being discharged to the storm drain system later.