Revised On: March 15 th, 2024 - 9:30 a.m.

Learning Objectives:

• After completing this lesson, you will be able to:
• Describe regulations that impact car washes
• Identify permits needed for car washes
• Describe what sludge at a car wash is

Wastewater and Sludge Management

The state of Arizona created guidelines and rules that conform to the Clean Water Act, which is a federal law that governs water pollution. Arizona aims to restrict pollutants and waste that enter storm drains and waterways. Substances dumped directly into storm drains can impair water quality and lead to Clean Water Act violations. ADEQ also has an Illegal dumping program that manages illicit solid waste discharges and improper disposal. Commercial car washes must obtain specific permits that detail safe disposal methods. These permits typically include instructions on the types of chemicals and detergents used, disposing of wastewater properly, and managing sludge effectively.

Along with the permit, car washes must have a best management practices (BMPs) plan outlining the measures to prevent pollution. BMPs typically include strategies such as using eco-friendly products, properly disposing of chemicals, and adequately maintaining equipment to prevent leaks and spills.

Clean Water Act and Arizona’s Discharge Permit 

The Clean Water Act establishes a program to “restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” In 1987, Congress directed the EPA to develop a regulatory program to address stormwater. In response, the EPA issued regulations in 1990 that authorized the creation of a National Pollutant Discharge Elimination System (NPDES) permitting system. On December 05, 2002, the EPA authorized Arizona to operate the NPDES Permit Program (Section 402 of the Clean Water Act) at the state level under the Arizona Pollutant Discharge Elimination System (AZPDES) Permit Program. Facilities that discharge pollutants from any point source into U.S. waters are required to obtain coverage under an AZPDES permit. The EPA defines point-source pollution as any contaminant that enters the environment from an easily identified and confined place. Runoff from a car wash event can be categorized as a point source discharge if it directly enters surface waters, a storm sewer system, or other conveyance. 

In conjunction with the AZPDES program, the State of Arizona also administers the sewage sludge program that aligns with the requirements of sections 402 and 405 of the Clean Water Act. All facilities that discharge pollutants from any point source into waters of the United States (navigable waters) must obtain or seek coverage under an AZPDES permit. Navigable waters refer to wide and deep waterways that can accommodate vessels, including rivers, lakes, and canals.

Permits Needed for a Car Wash

If you discharge any wash water from your business, you may need a Type 3 General Wash Permit for your vehicle and equipment. This permit allows for wastewater discharges from washing cars and equipment. Still, it doesn't cover sanitary sewage discharges, vehicle lubricating oils, antifreeze, gasoline, paint, varnish, solvents, pesticides, or fertilizers. It also does not cover releases from washing the interior of vessels used to transport fuel products or chemicals or the washing of equipment contaminated with fuel products or chemicals.

If your discharge or operations don't conform to the rule, the business must obtain an individual Aquifer Protection Permit (APP). This lifetime permit is required for facilities that discharge a pollutant directly to an aquifer, land surface, or subsurface where it's probable that the pollutant will reach an aquifer.

Lastly, if the facility utilizes reclaimed water, you'll need a Type 2 Reclaimed Water General Permit to reuse Class A+ reclaimed water directly. This applies to vehicles and equipment washing and is valid for five years.

RCRA and Sludge 

The Resource Conservation and Recovery Act (RCRA) of 1976 is a federal public law that oversees the management of hazardous and non-hazardous waste from cradle to grave. It identifies specific characteristics of solid waste that necessitate particular disposal methods.

For a material to be classified as hazardous waste, it must first be considered solid waste. The Environmental Protection Agency (EPA) regards solid waste as garbage, refuse, sludge, or other discarded material, including solids, semisolids, liquids, and contained gaseous materials. If your waste is defined as solid waste, you must determine whether it qualifies as hazardous waste. The EPA considers waste hazardous if it is on hazardous waste lists or exhibits hazardous characteristics. RCRA hazardous wastes are given a code (e.g., D001, D002, etc.).

If a facility needs to dispose of hazardous waste, it must follow the appropriate guidelines to prevent harm to the environment and human health. Facilities that generate or transport hazardous waste may need to obtain an EPA ID number under RCRA and will need to follow a set of management standards. An EPA ID number gives the EPA a general description of activities at sites that handle regulated wastes and is required if you generate over 220 pounds of hazardous waste in a month. The EPA ID number is used to track hazardous waste from its point of origin to its final disposal. If you are uncertain whether you require an EPA ID number or how to dispose of hazardous waste properly, contact ADEQ.

For a car wash, the most commonly generated hazardous waste is sludge. Sludge, also known as biosolids, is a type of solid waste consisting of accumulated dirt and grime residue found at the bottom of wash pits, grit traps, mud traps, and sumps of car washes. The material may contain high levels of oils and grease, heavy metals, detergents, phosphates, solvents/cleaners, and petroleum hydrocarbons. Arsenic, Barium, Benzene, and pesticides are among the dangerous substances found in sludge, which could be deemed hazardous under RCRA regulations. Although cars typically do not carry enough toxins to be considered hazardous, testing the sludge before disposal is imperative, as it is impossible to know what substances are present before washing. Determining your waste type is essential to legal and proper disposal. After running tests, if the waste is deemed non-hazardous, it can be disposed of at a solid waste landfill. However, in situations where the composition of the sludge is unknown, it is best to take additional precautions.

Illegal dumping of solid waste may result in prosecution as a felony or misdemeanor (A.R.S. § 9-499, § 11-268, and § 13-1603). Therefore, it is imperative to dispose of the sludge only at authorized locations. Specialized facilities are available to transport and dispose of your sludge, but only use licensed businesses for this purpose.

While obtaining permits for wastewater disposal and following waste regulations may feel daunting, their purpose is to guarantee business and environmental safety. The manager or business owner must know the pertinent regulations and rules; however, it's equally important that employees are also familiar, as they also have a responsibility and a unique opportunity to ensure guidelines are followed.

In the next lesson, we will learn about the types of car washes.