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City of Eugene <br /> Industrial Source Control <br /> Wash Water <br /> Memo <br /> To: Peter Ruffier <br /> From: Gary Cloyes <br /> Date: March 4, 2003 <br /> Re: Wash Water Issues <br /> This memo outlines some of the challenges faced in the regulation of wash water activities under the City's <br /> stormwater permit program, and the need for policy clarification in addressing ongoing issues. <br /> Wash water activities include such functions as vehicle washing, equipment washing, cleaning of exterior <br /> building, sidewalk, and pavement surfaces, and exterior window washing. Under current City policy only <br /> industrial and commercial wash water operations are regulated in the stormwater program(through the <br /> issuance of 1700A NPDES permits). Residential washing activities by home owners and fund raising <br /> groups are not regulated. <br /> ISSUE: Excessive Charity/Non-Profit Car Washing Activities <br /> Wash water activities defined as"Deminimis Activities" by the state Department of Environmental Quality <br /> (DEQ)do not require a 1700A NPDES permit. Included in the list of deminimis activities are Non-Profit <br /> Activities which are defined as: <br /> r Vehicle washing by private citizens and fund-raising groups such as schools, churches, Boy <br /> Scouts, etc. is permitted. Fund-raising groups shall employ the Best Management Practices <br /> (BMP)outlined in the Department's fact sheet(attached)for non-profit activities. <br /> DEQ allows charities to conduct car washes without a 1700A permit providing they comply with all BMP's <br /> listed in the fact sheet, including a BMP which limits the frequency of car washing to one event per month. <br /> City staff has observed this limitation being exceeded on numerous occasions. The following are two <br /> examples of organizations exceeding this once a month limitation. <br /> Charity group(Victory Out Reach of Eugene)seems to be making a business out of washing vehicles. <br /> They have been operating several days each week for the past month (as observed by Industrial Source <br /> Control(ISC)sampling team)at West 11th &Oak Patch. Typically those organizations which conduct <br /> frequent washing events(every week)are out-reach type programs which have people available everyday <br /> to wash vehicles. Willamette Family Treatment Services(1420 Green Acres Road)is another organization <br /> which conducts multiple washing events each month. <br /> Our practice has been to not regulate charity car washing events. If a group contacts us,we provide them <br /> with DEQ's Wash Water BMP fact sheet for Non-Profit Activities and encourage them to conduct washing <br /> on pervious surface areas(gravel or grass)and not discharge to the stormwater conveyance system. <br /> Surprisingly most concerns/complaints we receive are from City employees and not the general public. <br /> 1 <br />