Mobile Washing Policy

1. Mobile Washing Policy • Florida Statutes Section 403.087 contain the basic requirement for DEP regulation. • Must be a stationary pollution source, such as a fleet maintenance lot. • Does not reference disposal of the wastewater in the Statute as a criteria. • Statute requires a permit or exemption.

2. Different Types of Systems • Surface Water Discharge-NPDES • Ground Water Discharge: Sprayfield, Drainfield, Spray Irrigation, French Drain • Recycle System-Only 100% Counts • Connected to Sanitary Sewer, With the Utility’s Approval • Pump and Truck Wastewater Elsewhere

3. What Does an Exemption Require? • No Surface Discharge Can be Exempted. • Rules Do Not Have Specific Standards for Exemptions. • No Reasonable Potential for Pollution • Identify a Best Management Practice-BMP • Sell Your Proposal, Provide Support

4. What You Need to Know About an Exemption? • No Fee • No Forms • No Engineer • The Key Is to Present Your Site Specific Proposal On the No Reasonable Potential Basis. • Worst Case?-Permit required.

5. What Are a Mobile Washer’s Obligation? • Being Mobile, Vendors/Contractors Do Not Need Formal Approval Under the Statute. • Your Client at a Stationary Facility Has The Obligation for Approval. • Liability Remains for Violation of Surface/Ground Water Standards. The “Free Froms” Apply at All Times and Places.

6. What Are the Client’s Obligations? • Either Connect to Sanitary Sewer, or • Have a Service Haul the Wastewater to an Approved Disposal System, or • Comply With the Statute by getting an Exemption or Permit. • Yes, a Vendor/Contractor May be an Agent to Apply for the Exemption or Permit on The Facility’s Behalf.

7. What Would Prevent an Exemption Approval? • Any Potential For Surface Discharge. • Washing Garbage/Solid Waste Trucks. • Degreasing Parts/Engines • Cleaning Tankers Internally/Steaming Undercarriages • Any potential Impact On/Off Site Wells/Property • Use of Solvents/Strong Chemicals

8. Ok Then, A Permit • Not Required for Sanitary Sewer Connection. • Pretreatment Before Sanitary Sewer Connection-Still No Permit Required. • If a Permit is Required, So Is a P.E. • Recycle or Not to Recycle? That Is The Evaluation That the P.E. Is Paid to Make.

9. Recycle System Trade Offs • Negatives: • Higher Treatment Quality Needed • Higher Capital Cost to Build the System • Has More Maintenance Due to Complexity • Wastewater Becomes “Spent”-Must Pay Hauler • Waste Oil and Sludge for Disposal

10. Positive Trade Offs • Application Fee Is Less: $200 vs.. $1500 on the Smaller Systems and Renewals for Half That Every 5 Years. • Engineering Fees Associated With Application Are Less Due to Simple Engineering Report. • No Routine Samples Required.

11. Ground Water Discharge • Might Still Get an Exemption for Small Systems Based on a BMP. • Land Application System: Pond, Drainfield, Sprayfield- DEP Has No Preference. • Less treatment May Be Needed-Less Capital/ Easier to Maintain • Does Have Sampling Unless Exempt

12. What About That Ditch Beside the Property? • Should Not Be Considered Until All Other Options Have Been Rejected. • Why?-Too Expensive to Meet Discharge Standards. Anti-Degradation Report. • Needs a Level Of Treatment That a Small Business Cannot Afford. • Continuing Tests and Toxicity Analyses

13. Isn’t That a Lot? • Florida Was Given Delegation for a Federal Program May 1, 1995. • Governs Surface Discharges • Eliminates Exemptions for Surface Discharges-No Discretion Allowed • NPDES-National Pollutant Discharge Elimination System

14. Oil-Water Separators • These Are Just Another type of a Treatment Unit, Such as Filtration or Settling. • Does Not Determine Permitting Requirements. • Directions on Previous Slides Apply. • Best Designs Have an Off-Line Holding Tank for the Waste Oil.

15. But I Already Have a Pond Out Back • Most Likely That Was Designed as a Stormwater Pond. • Holds Runoff From the First Inch of Rainfall, Then Discharges Off Site. • Evaluate Any Potential for Discharge, If so Then NPDES Rules Apply Again. • We Would Be Conservative In View.

16. It’s Just a Bit of Water, How About My Septic Tank? • Septic Tanks Are Regulated by The Dept. of Health. • They Have a Rule Too, Thou Shall Not Put IW Into a Septic Tank. • DEP Cannot Authorize Your Use of a Septic Tank For Any IW or DW Purpose. However a Treatment System May Use the Tanks in Various Treatment Components, i.e. Settling Tank.

17. Potable Water Well Protection • Carpet Wastes Must Not Be Discharged: • Within 100 feet of a Public Water Supply Well (Rule 62-555 FAC). • Within 75 feet of a Private water Supply Well (Dept of health Rule) • Within 75 Feet of Surface Waters • Where Ever Such Discharge Would Cause nuisance Conditions.

18. Who Do I Contact at DEP? • For More Clarification of These Issues, Application Forms and Permitting Matters Call Ali Kazi at 407-893-3316 or Gene Elliott -3317. • For Field Evaluation, Complaints or Help in Preparing Reports Call Gary Miller at 407-893-3986 or Kalina Warren -3313.

19. County Rules • In the Eight Counties Regulated by the Central District only Indian River County Does Not Have a Local Environmental Program. • None Are Delegated Responsibility From the State for the IW Program. • Each Local County Program May Have Regulations That Apply to Your Business. • We Encourage You to Check With the County.