July-August 2005

Illicit Discharge Detection and Dry-Weather Flows

Targeting unexpected sources of pollutants

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By Bill Tice

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Although the stormwater drains in most municipalities are designed to process rain runoff, stormwater managers frequently find they are dealing with other substances that have been introduced to the stormwater system, from contaminants that are inadvertently flushed down the drain by unsuspecting homeowners to illegally dumped effluent from commercial ventures.

The latter is an issue for Cathy Parker, president of Parker West International LLC in Santa Rosa, CA. Parker just wants to compete on a level playing field, but she contends that illegal dumping, and the lack of enforcement of the clean-water laws toward mobile pressure-washing companies and their customers, makes this difficult. Parker’s company is in the commercial pressure-washing business and cleans surfaces at gas stations, parking lots, shopping malls, transit stations, and other commercial and industrial establishments. But as a good corporate citizen, she refuses to contaminate the stormwater system just to be the low bidder on a job. Instead, Parker West collects and cleans the wastewater as it pressure-washes.

“Our outdoor surfaces need to be cleaned so that pollutants entering the storm drain during rainstorms are reduced,” explains Parker. “However, the wastewater generated by pressure washing contains a complex matrix of contaminants, which includes varying levels of oil, grease, metals, gum, and paints, along with the cleaning agents. For example, on average, for every six parking spaces we clean, we are removing 1 quart of spilled automotive fluid, and 1 quart of used motor oil can contaminate 250,000 gallons of fresh water.”

Although most cities have regulations in place that disallow the dumping of this wastewater directly into the storm drains or sewer system, Parker says this is still the leading method of disposal for many power-washing companies because of the cost of proper disposal and the lack of enforcement. “Most cleaning activities at commercial businesses take place at night when the inspectors are not on duty, and even when violators are caught, the fines are either waived or are so small that it is more economical for the violators and the companies that hire them to continue dumping than to either process the waste or manifest, haul, and dispose of the wastewater properly.”

Rather than use this illegal and environmentally damaging method of disposing of the wastewater, in 1996 Parker West invented and patented a mobile wastewater processing system, which collects and cleans the wastewater in one step within minutes. This is done on the site of the cleaning operation and before disposing of the clean water into the sewer system. She contends that doing things right doesn’t really add a great amount to the project cost, but it is enough, in many cases, for Parker West to lose the business. Parker West’s price averages $0.01 to $0.02 per square foot more than the pressure washers who mismanage their wastewater.

Parker points to one of her clients as an example of doing things the right way. Chec Consultants Inc. is a 100% Web-based company with headquarters in Old Station, CA. “Chec is a consulting engineering company that specializes in asphalt construction. They recommend our services to their clients who need to remove failed seal coat from the streets, which will start to chip off if it has not been applied properly. We come in and pressure-wash the surface and remove the loose chips so that the surface can be recoated.”

PHOTO: CONTRA COSTA COUNTY
Garbage pileup at culvert behind small business, 2002

The solid waste (asphalt chips and seal coat) that Parker West removes from the wastewater becomes permanently fixated, rendering a nonleachable, Class II nonhazardous waste, which can be disposed of for $70 per ton. “The only other environmentally friendly alternative for these types of projects would be to collect and haul the 20,000-plus gallons of contaminated wastewater from each job as hazardous waste,” adds Parker, who estimates the cost for Parker West to treat the wastewater onsite at $0.05 to $0.07 per gallon and the cost of hauling the wastewater to an approved disposal site at somewhere between $0.75 and $1.20 per gallon. “Despite the small cost of treating the wastewater, many companies won’t take this step, and instead discharge directly to the storm drain or sewer system without pretreatment,” she adds.

“We believe in zero discharge to the storm drains, and we have been using our wastewater treatment technology for eight years now, but we are still competing against companies who mismanage their wastewater,” notes Parker. “Ninety-five percent of the time when we are asked to bid on a project, even for the government, it is the company that bids the lowest price that gets the job. Our pricing is very competitive, but by doing things right, we are not competing on a level playing field.”

That may change for Parker West this year, as it is set to introduce a prototype of a “driving pressure-washing machine” to the California market. “This is the first driving machine ever invented for pressure washing,” explains Parker. “We asked the machine’s inventor to develop this piece of equipment as an accessory to our current treatment technology.”

The new machine will be connected to the Parker West mobile wastewater treatment system, which is mounted inside of a trailer, and the operator will be simultaneously cleaning and processing the wastewater. The speed of this driving pressure washer will help Parker West make up for the extra cost in its bids for proper management and disposal of the wastewater and solid waste. “With this machine, we will be able to pressure-wash at two to three times the speed of other pressure washers who are walking,” notes Parker. “We will also incur reduced manpower, labor costs, and worker fatigue. The bottom line is that we will be able to compete with other pressure washers and remain compliant with the clean-water and solid waste management laws that have been established to protect our environment.”

PHOTO: WAYNE COUNTY

According to Robert Hinderliter, president of Delco Cleaning Systems of Fort Worth Inc., of Fort Worth, TX, the regulations concerning the disposal of wastewater from pressure washing are confusing at best. Hinderliter is also the founder of the Power Washers of North America (PWNA), a nonprofit organization, which now numbers in excess of 500 company members.

“Educating the pressure-washing industry in proper disposal methods and environmental awareness is one of the mandates of the PWNA,” says Hinderliter, who today is the environmental chairman of the association. “What it comes down to is that the municipalities will tell you that they don’t want anything down the storm drains, and what we have found is that there will be a high level of compliance if the regulations are reasonable, rational, and logical, but in most municipalities the regulations are not reasonable, rational, and logical, and enforcement is not always high on the municipalities’ priority list.”

Hinderliter says the problem is compounded by the fact that almost anyone with a vehicle and an extra $100 can be in the power-washing business. “Entry into the power-washing business requires a minimal investment with entry-level pressure washers available at consumer hardware stores for under $100. Many of the people who get into this business do it on a part-time basis, primarily at night and on the weekends, when enforcement is at its lowest.”

Through Delco Cleaning Systems of Fort Worth Inc., Hinderliter offers training, including “how to” schools, equipment, chemicals, and training solutions, while for the PWNA, he conducts seminars and speaks on its behalf at conferences nationwide.

Different Neighborhoods, Different Pollutants
But pressure washers are not the only problem when it comes to contaminants in storm drain systems. Elisa Wilfong, a watershed management planning specialist with the Contra Costa Clean Water Program in California, occasionally sees the effects of illegal dumping as part of her day-to-day work.

“We head the clean-water program for Contra Costa County, its 19 cities, and the Contra Costa County Flood Control and Water Conservation District, which are under the National Pollution Discharge Elimination System [NPDES] permit requirements,” notes Wilfong. “We work on a number of different things, including education, outreach programs, illicit discharge issues, and stormwater inspections.” Contra Costa County, a diverse county in the San Francisco Bay area, is the second largest industrial county in California; only Los Angeles County has more industrial business. But Wilfong says in most cases, the public and industry want to comply with the regulations regarding the stormwater system.

“We find in most cases, both with industry and the public, the violations are the result of a lack of education. They are not trying to pollute, but it is a case of ‘out of sight, out of mind,’ and many people just don’t understand the environmental impact of what they do.”

Wilfong says with the public, there are a lot of gray areas when it comes to the stormwater systems. “Under our NPDES permit, it is only supposed to be ‘rain down the drain,’ but if the municipality can prove the water off your driveway or from your pool doesn’t contain pollutants, then you are exempt. You can’t go around and inspect everyone’s water, so we try to educate as much as possible. We encourage people to use nontoxic soap or no soap, and to drive their cars onto the lawn for washing so that the soapy water doesn’t go down the storm drain, or even better, to go to a place like a commercial car wash that is plumbed to the sanitary sewer and not the storm drain. Soap manufacturers will say the soap is biodegradable, but if it gets into the waterways, it can still kill fish by decreasing the oxygen levels in the water.”

With a county as diverse as Contra Costa, Wilfong notes that the types of pollution vary by area. “In the eastern, more rural area of the county we have to deal with random dumping of things such as batteries, appliances, e-waste, tires, and other used household items that can seep chemicals into the ground, which will eventually reach the water table. In some of the more populated areas, a lot of industry and poor education will contribute to the problem. It depends on the demographics, but each municipality within the county will identify hot spots where illicit discharge is more prevalent, and our outreach is done from there outwards.”

As for commercial enterprises, Wilfong says most companies don’t try to pollute on purpose and will do what they can to stay within their permits. “We get the odd business that will plumb illegally to the creek, but for the most part, the industries within the county try to do what is right. However, there are some things that are beyond our control. This is the case with fire prevention and spills from truck accidents. Safety comes first, but the foam used by fire departments can seep into the stormwater systems and creeks, as can hazardous waste from spills related to truck rollovers.”

Temperature Differences Reveal Hidden Leaks
On the other side of the country, Marian Page is also very involved with educational and outreach programs. Page is the Coastal Nonpoint Program coordinator for the Office of Ocean and Coastal Resource Management (OCRM), which is a division of the South Carolina Department of Health and Environmental Control (SCDHEC). The OCRM is responsible for the protection of the coastal environment for the state’s eight-county coastal zone and also promotes responsible development along the South Carolina coast.

“The OCRM has two divisions, a Planning Division and a Regulatory Division,” notes Page. “I work for the Planning Division, and we administer a number of different programs and initiatives. We work with the local governments, we put on workshops to encourage alternatives in subdivision design, we introduce best management practices for the stormwater systems, we produce publications that deal with topics such as vegetative buffers and stormwater pond maintenance, and we have a staff person who deals with septic systems and works closely with the counties to develop ordinances and inspection programs.”

With the coastal nonpoint program focusing on nonpoint-source pollutants that affect the coast, such as leaking septic tanks, Page became involved with a pilot project with the SCDHEC’s Environmental Quality Control Division. The project involves surveying areas where shellfish have been affected by fecal coliform contamination.

“In order to be more efficient, we started a pilot project in the fall of 2004 using thermal imaging,” notes Page. “Thermal imagery has a broad, practical capability to assist coastal managers with the identification of threats to water quality. In particular, it has been useful in helping the coastal shellfish managers narrow the focus of their monitoring efforts to identify potential sources of fecal coliform bacteria. We are excited about the possible applications of thermal imaging technology and are currently working with shellfish management staff to conduct ground truthing and water-quality analysis.”

The thermal imagery project was funded by a grant from the Coastal Nonpoint Program, which is a National Oceanic and Atmospheric Administration–funded grant program administered by the SCDHEC/ORCM.

The technology used for the project is called Pollution Finder from AITscan, a division of Stockton Infrared Thermographic Services Inc. in Greensboro, NC. AITscan uses a specially designed aircraft with an opening in the bottom of the plane, where the camera is mounted. A 60-Hz camera records a live NTSC-format video signal, outputting a grayscale picture with the scales (or shades of gray) representing the differences in temperature and emissivity of objects in the image. As a general rule, objects that appear lighter in color are warmer, and darker objects are cooler. The ground a short distance below the surface is warmer than the ground-surface temperature, so any liquid coming up from below the ground level, such as from a leaking septic system, is warmer than the surface temperature and will show up as a lighter gray on the output.

Expanding the Program
Wayne County, MI, is recognized as a leader in illicit discharge detection and elimination. The jurisdiction, which includes the city of Detroit, has been in the limelight for its efforts before, but the Wayne County Department of Environment isn’t sitting back and relying on its reputation to curb future illicit discharges and connections. In the past, Wayne County has used a number of different methods to detect problems in its water systems, including dye testing, underground closed-circuit television surveillance, water sampling, and smoke testing. But today, the county is stepping up its efforts with some new tools of the trade.

PHOTO:RIVERSIDES STEWARDSHIP ALLIANCE

“We are trying to expand on the different techniques we use to find illicit discharges and connections,” notes Susan Thompson, an environmental specialist with the county. “We have started to do some remote monitoring with automated samplers in the storm drains to see if the parameters change at certain times of day. We especially look for spikes in the numbers during the evening hours, as this is when illegal dumping is more likely to take place, but the automated samplers collect samples a number of times during a 24-hour period.”

The automated samplers are portable, so the county moves them around when there is a problem it has not been able to isolate during initial investigations. “You can pick your hot spots,” adds Thompson. In addition to the automated samplers, Thompson says Wayne County has also introduced multiparameter sondes to its tool kit. The sondes collect conductivity and temperature data, although they can be used for other parameters as well. “From the conductivity and temperature readings, we can tell if there is a problem, as these two parameters should be constant. If we are seeing spikes and dips in conductivity and temperature, we know something could be wrong, and dumping could be happening. The nice thing about the sondes is that you can set them out and leave them, and every 15 minutes they will collect a measurement. This is much better than someone going out to take readings as there is less manipulation of the samples, and this gives us a better picture of the water quality.”

Wayne County initially launched its program in 1987, aimed at detecting and eliminating illicit discharges and improper or illegal connections to the county’s storm sewers and surface waters. Fifteen years later, at the end of 2002, the county reported that it had inspected 5,420 commercial, retail, and industrial facilities for illicit connections and discharges, and field staff had found 1,433 violations at 370 facilities. Two years later, at the end of 2004, Wayne County’s Illicit Discharge Elimination Program had inspected 6,317 facilities since the program’s inception and had found 1,483 violations at 493 of the sites.

“It is estimated that eliminating these illicit discharges and connections prevents 13 million gallons of polluted water and 1 million pounds of polluting material from entering the surface water of Wayne County annually,” says Thompson. “The water quality, especially in our watershed, has improved. If you eliminate one pipe at a time, you can knock out a significant pollution load.”

Education is a big part of the Wayne County program, and with success locally, interest in the program has spread to other counties and municipalities—not just in Michigan, but also across the country. “We have put 1,200 people through our workshops, and we developed a video through a training grant,” says Thompson. “We were even asked to go to Duluth, Minnesota, to do the training for their staff.”

Focusing on Lot-Level Pollution
As the executive director of RiverSides Stewardship Alliance in Toronto, ON, Kevin Mercer spends much of his time building cooperative partnerships with municipalities, watershed organizations, and businesses across North America. For 10 years RiverSides’ agenda has been watershed-source protection and the adoption of community-based source-protection programs, and more recently best management practices (BMPs) that address lot-level runoff and community-based nonpoint pollution sources. RiverSides is a nonprofit advocacy and consulting organization that works to protect and restore watersheds by reversing the alarming trend that sees a large percentage of watershed pollution originating from city streets and urban lots.

Since its inception in 1995, RiverSides has delivered direct social marketing programs that educate the public about the connection of their homes to their watershed, and about contaminated runoff from household activities—for example, pressure washing and car washing. More recently, the organization has focused attention on comprehensive low-impact development for new-build and retrofit neighborhoods.

“We are fine-tuning our program and emphasizing low-impact development,” notes Mercer. “The object of low-impact development is to intercept and hold rain flows that would otherwise go into the storm system, taking pollutants with them. To accomplish our objective, we are promoting lot-level detention and infiltration by means of rain barrels, French drains, and property regrading for rain gardens. All of these BMPs effectively reduce the amount of water going into the storm system.”

As a nonprofit organization, RiverSides funds its watershed education programs through a combination of sponsorships and donations, but also sells consulting services to municipalities, including its 5 Things You Can Do For Your River program and the RiverSafe RainBarrel BMP program. “Most rain barrels are undersized and are mostly detractors of this method of reducing runoff. Municipalities across the US and Canada that know the value of effective stormwater management seek us out and order RiverSafe RainBarrels.”

RiverSides is also widely recognized for its RiverSafe Carwash Campaign, which promotes ordinances and social marketing education to eliminate personal and community fundraising car wash runoff pollution. The campaign targets driveway and parking lot washing that creates a small but toxic flow of detergents, surfactants, oils, rust, engine grime, wax, and degreasers that flow into the storm sewer and discharge untreated to nearby water bodies. RiverSides encourages the use of commercial car washes, which the organization says use half as much water as washing your car at home, but more importantly, the wastewater from these commercial washes does not go into the waterways untreated.

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For community fundraising events in Toronto, RiverSides lends out the same package it sells to municipalities for community group car wash fundraisers: two Latimat car wash containment pads to prevent wastewater runoff, a power washer, a sump pump, and supportive educational materials concerning watershed impacts of car washing. The Latimats “are high-sided thick poly material pads, approximately 30 feet by 10 feet,” explains Mercer. “We lend them out with a power washer, and by using these mats, community car wash runoff wastewater is prevented from being just another source of nonpoint pollutants that degrade our watersheds and drinking-water supplies.”

Author Bill Tice is based in Blaine, WA.

Author's Bio: Author Bill Tice is based in Blaine, WA.

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