Transcript Mobile Washing Policy • Florida Statutes Section 403.087 contain the basic requirement for DEP regulation. • Must be a stationary pollution source, such as.

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.
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
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
What You Need to Know About
an Exemption?
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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.
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.
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.
What Would Prevent an Exemption
Approval?
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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
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.
Recycle System Trade Offs
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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
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.
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
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
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
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.
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.
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.
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.
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 407893-3986 or Kalina Warren -3313.
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.