The Clean Water Act (CWA)
The clean water act “is the principle law governing pollution control and water quality of the U.S. waterways.” The objective of the act is to restore and maintain the chemical, physical and biological integrity of the Nation’s waters. [url= http://www.epa.gov/watertrain/cwa/]CWA[url] Section 301 of the Clean Water Act (CWA) prohibits a point source discharge of pollutants into waters of the United States without an NPDES permit. To legally discharge wash water, a pressure wash operator must obtain an NPDES permit for each discharge location. Due to the fact that many pressure washer operators are mobile, it is not realistic to pre-determine discharge locations and obtain permits for each location. Additionally, most NPDES permitted process water discharges require treatment and analysis of the discharge, which may not be practical for many pressure washers.
The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States. If your discharge does not reach waters of the United States, then there are no requirements under the CWA. Examples of compliance without a discharge are vacuuming up the process wastewater or berming the process water and allowing it to evaporate. An additional method of compliance is to discharge the water to an NPDES permitted sanitary sewer system (the municipality may have additional pretreatment requirements before accepting your discharge). The most common form of non-compliance is to discharge the process water into a storm sewer system or into a city street that drains to a storm water inlet. Most storm drainage systems in Region 6 discharge directly to waters of the United States without treatment, which means anything that discharges into a storm drain is the same as putting it directly into the water body receiving the storm drain discharge.
What does this mean to you as a property manager or owner?
You are responsible for the actions and reclaiming procedures of your mobile pressure washing contractor. March, 2004, the clean Water Act administration raised the penalty for class 1 penalties to over $30,000 and class 2 penalties to over $150,000. Violations to the CWA can cost up to $11,000 a day for each day of illegal operation. Use caution when hiring a mobile pressure washing contractor, and make sure they comply with EPA standards.
Mobile Truck Washing and the EPA
This industry is increasingly becoming more and more environmentally conscience. If you own a fleet washing company chances are you know what reclamation is. BMP’s (Best Management Practices) often include the reclamation of all waste water used in the mobile truck washing process. The methods for reclamation can be as simple as you make them. With that being said they can also be as difficult and expensive as you make them. Visit theFleet Washing Academy to learn more on the processes and procedures.
What does this mean for the small fleet washing outfits? It’s simple get compliant or risk everything. Make a sincere effort if nothing else to show the EPA in those bad situations that you are at least attempting to become compliant. You can become compliant with a small investment and some set up time before each job. Fleet owners and managers are becoming more and more aware of the EPA standards and requiring that their fleet wash contractor reclaim all waste water. This means if you do not become compliant large fleets will not even consider your company for the contract. This is a wave of regulations moving across the entire pressure washing industry.