An effective wash rack system is the best way to wash equipment and protect property value.
Washing equipment on the “south 40” and letting the water run onto the ground or into the storm drain can cost a rental company thousands of dollars. The 1987 amendments to the Clean Water Act combined with the Safe Drinking Water Act enforces a legislation that makes it illegal for industrial wash water to run to the ground, storm sewers and septic tanks.
Wash water generated from cleaning equipment typically contains a number of pollutants, including oil, grease, heavy metals and chemicals. The EPA requires that wash water be treated before it is dumped into a sanitary sewer, or Publicly Owned Treatment Works (POTW), and prohibits dumping or storing it in areas that can cause soil and groundwater contamination.
Fines for negligent violations start at $2,500. Although fines can reach six figures, government enforcement in most states remains to be minimal. As Rick Soto of All American Equipment in North Hollywood, Calif. explains, “there has been no real enforcement except in California and Florida.” But it isn't the potential fines that cause the most concern. The erosion of property value can cost a business a whole lot of green.
“In spite of the lack of legal enforcement, many companies are going to the expense of putting in recycle systems or sewer discharge systems without being warned or cited by the government,” says Jeff Taylor, project manager of the Water Treatment Division of Peosta, Iowa-based Mi-T-M Corp. “They tend to be more concerned with the protection of the property, whether leased or owned.” Years of washing equipment out back and exposing the property to constituent-laden water can create a serious liability; it can actually transform a rental company's largest asset into its worst nightmare.
“The old adage goes like this: ‘I've been dumping this water out in the backyard for the last 20 years, and I don't need a water treatment system’,” says Bernie Larson, national account sales manager of Landa Water Cleaning Systems in Camas, Wash. “However, to continue this practice means that contaminants are concentrating on their property. Someone will eventually have to pay to clean it up.”
Cradle to grave
The EPA's “cradle to grave” provision as defined by CERCLA, (Comprehensive Environmental Response Compensation and Liability Act, Superfund) holds the waste generator responsible for proper waste disposal. Therefore, by a legal standpoint, the generator owns his waste, just as he owns his property. “Any contamination you generate as a business, you are responsible for from cradle to grave,” Taylor says.
When a property owner goes to refinance or sell his or her land, the bank requires a Phase 1 environmental audit. If signs of negligence or potential contamination are suspected, a Phase 2 audit will require core samples of the soil. The property owner will be required to perform a cleanup if high levels of contamination are detected in the core samples. The property cannot be sold until the cleanup is completed.
If a property owner leased to a rental center that generated the contamination, it would then become the responsibility of the rental center to pay for the cleanup. Cleanups can be extremely expensive and time consuming, and create the largest risk involved with wash water run-off.
A wash water treatment system has become a vital component of a successful rental operation. Pricilla Oehlert, director, risk and safety of Scottsdale, Ariz.-based Rental Service Corporation, explains, “We have established and implemented a formalized wash rack program for all [our] rental locations.”
The right rack
Wash racks, or water treatment systems, must be custom designed to meet the needs of the rental center. “Every situation is different,” says Soto. “A lot of people think you can use a cookie cutter and get these systems out, but it's not going to cover everyone's needs.”
When installing a wash rack, it is extremely important that the rental center contact an expert to assist in designing the pit system. “If they just buy a piece of equipment and don't know much about pit design, they could have a very expensive problem on their hands,” says Taylor (see Consider This).
“When designing a wash water treatment system, one of the first considerations should be what to do with the water generated in the washing process,” says Larson. “There are three primary options: a) sewer discharge to a POTW, b) recycle the water, and c) contain the water and haul it off-site to an authorized disposal site.”
If possible, “discharging to the sanitary sewer should be the first recourse,” Taylor says. “The equipment is less expensive and the ongoing maintenance is less demanding.” However, the POTW enforces certain discharge limits in terms of volume and contaminant levels based on their overall capacity to treat water and it is common for those limits to change. “Just because you have a sewer connection today, doesn't mean you will have one tomorrow,” Larson adds.
Recycle systems, or closed-loop systems, offer a zero-discharge solution to the wash water dilemma. Regular maintenance is required and components need to be cleaned of buildup, which needs to be disposed of properly. “The first rule of thumb with recycling water is to remember that water cannot be recycled forever,” says Larson. “Eventually the contaminants build up to a point where you need to purge the system and start over with fresh water.”
Aboveground systems, or portable closed-loop systems, are an option that does not require concrete pads, pit systems and permits. Yet the cost of hauling wastewater can become expensive and a rental center will require the services of a certified hauler. “We go through a vendor certification process for [the haulers] to make sure that they transport to approved facilities, maintain the proper insurance and are credible,” Oehlert says.
The initial investment in a wash rack can range anywhere from $8,000 to $100,000 or more, depending on the size of the operation and the costs of construction, cement work and equipment. If done correctly, the investment will serve to protect your business now and in the years to come.
“Ask questions,” says Soto. “Take care of business now. If not it will come back and bite you.”
What are your washing needs? How much water and dirt is generated in the washing process?
Do you have access to the sanitary sewer? What are you maximum discharge limits?
What permits will you need to obtain?
What is your largest piece of equipment that will need regular washing? (also consider what equipment on your fleet can be used for pit cleaning)
If you don't have access to the sanitary sewer, do you have a certified hauler?
How much maintenance will your system require?
Information provided by Jeff Taylor, Mi-T-M