Environmental Stewardship Advisory Commission_Car WashesJanuary 12, 2010
Honorable Mayor Roy Buol and
City Council Members
City Hall
50 W. 13th Street
Dubuque IA 52001
RE: Fundraising car washes and stormwater management
Dear Mr. Mayor and Council Members:
Clean water is one of the eleven sustainability principles of the City of Dubuque.
The Environmental Stewardship Advisory Commission is concerned about the amount
of fundraising car washes that occur in the community and their impact on stormwater
management. Waste from these type of car washes goes from a parking lot directly into
the storm sewer system. Non - profit groups hold these events very frequently in spring,
summer and fall months to raise money, and there is basically no City policy or
regulations for their occurrence. The attached article from the Journal for Surface
Water Quality Professionals highlights many of the issues regarding residential and
fundraising car washing.
The Environmental Stewardship Advisory Commission respectfully requests the City
Council consider developing a policy and /or ordinance for fundraising car washes in the
city. Members of the Commission would be happy to work with City staff and provide
input into development of such a policy /ordinance.
We hope you will consider studying this issue since it does impact the City's Stormwater
Management Plan and Best Management Practices.
Sinc rely,
Wayne Klostermann, Chair
Environmental Stewardship Advisory Commission
Aa lovroal for Surlasa W Itr Qua11IT Ptallsdinalf
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September 2009
Residential Car Washing
New data - and controversy - the state of Washington
Photo: & #169;iStock.com/Chad Truemper
By Dan Smith, Hollie Shilley
Portrayed as innocuous, residential car washing is a common scene during any weekend, in any cul -de -sac, in any
neighborhood, and in any city across America's vast patchwork quilt — including our town, Federal Way, WA. The
conventional wisdom for many washing their cars is this: Once vehicle wash water gets hosed off the pavement and
disappears down the drain, it is out of sight and out of mind.
Page 1 of 6
Society has been slow to recognize the link between individual behaviors and practices, and the detrimental impacts that
they may have on our natural aquatic resources. One of these practices, residential car washing, may give rise to
surface- water - quality problems that can be felt well beyond the front yards and driveways of the communities where it
occurs.
In some instances, car washing is carried out on lawns, in side yards, or on graveled areas. However, in most cases, it is
performed on impervious surfaces —that is, driveways or streets —where the wash water drains directly into the municipal
separate storm sewer system (MS4). In an attempt to better understand the nature of these discharges to the MS4 and to
quantify their potential impacts, the Water Quality section of the Surface Water Management Division of Public Works in
Federal Way embarked on a small study to illustrate the links between car washing, stormwater, local surface waters, and
Puget Sound.
Most citizens falsely assume that stormwater is treated before it gets to streams, wetlands, and other waterbodies. They
may ask, "What could be so dangerous in the harmless- looking white- with-foam river running into the street and oozing
headlong into a stormwater catch basin ?" For these folks, there are no apparent water - quality impacts, because from
every shoreline and bluff vantage point, their view of Puget Sound'appears as sparkling and unaltered as ever.
Fed by seasonal freshwater from the Olympic and Cascade Mountain watersheds, Puget Sound is a 90- mile -long
saltwater estuary in rapidly growing western Washington. This threatened waterbody provides recreation for people and
is home to a diverse, but endangered, ecosystem.
In 2007, the Washington State Legislature created the Puget Sound Partnership (PSP), an effort undertaken to
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implement a strategic and bold plan to restore this regionally important waterbody by 2020. At the end of 2008, the PSP
issued an Action Agenda that spells out measurable goals for Puget Sound's recovery by demonstrating the complex
connections between the land and water. With a good deal of alarm, the PSP emphasizes, in no uncertain terms, that
urban stormwater runoff poses a major threat to the ecosystem health of Puget Sound.
Photo: Daniel Smith
Foam from residential car washing runs into a storm
drain.
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The findings presented here show that most residential car
washing is a source of stormwater pollution. We are hopeful that
the release of this credible, community- based, homegrown
information will help the residents of Federal Way, as well as other
communities, connect the dots between their own actions, the
associated impacts, and their shared environmental
responsibilities.
Regulatory Background
Nearly 10 years ago, the EPA issued the National Pollutant
Discharge Elimination System (NPDES) stormwater Phase II
program regulations (40 CFR Part 122). In essence, the ruling was
a federal mandate established to address discharges from small
MS4s in an effort to reduce sources of stormwater pollution that
impact water quality.
The EPA's primary role in the NPDES program was to develop the
overall regulatory framework. Under the ruling, authorized states (including Washington) were permitted to tailor their
stormwater discharge control programs so that water - quality needs and objectives could be addressed through a fine -
tuning and adjustment of the regulatory process at a state level. In early 2007, the Washington state Department of
Ecology (DOE) issued the Westem Washington Phase II Municipal Stormwater Permit. More than 100 jurisdictions are
subjected to this permit, including Federal Way.
The Phase II rule requires that all affected municipalities implement a series of individualized programs designed to
control non - stormwater discharges, including both public education and procedures to detect and eliminate stormwater
pollutants (illicit discharges). With some exceptions, the EPA defines an illicit discharge as "any discharge to an MS4 that
is not composed entirely of stormwater."
As such, Phase II jurisdictions are to "effectively prohibit through ordinance, or other regulatory mechanism, illicit
discharges into the MS4, and implement appropriate enforcement actions as needed." The Western Washington Phase II
Municipal Stormwater permit requires the development of a regulatory mechanism by August 2009 that effectively
prohibits non - stormwater discharges, illegal discharges, and dumping into the MS4 to the maximum extent allowable
under state and federal law ® 1
By definition, residential car washwater is a non - stormwater discharge; however, the EPA ruling sets it and other types of
non - stormwater discharges (including water -line flushing, landscape irrigation, and dechlorinated swimming pool
discharges) apart. These discharges would only be included in the scope of an illicit discharge detection and elimination
(IDDE) program if they were identified as significant contributors of pollutants to the MS4. In these cases, a municipality
could require specific stormwater controls for the activity, or could prohibit the discharge completely.
If this sounds vague, it's because it is. A former EPA senior analyst with the Office of Water stormwater programs admits
that the permit is "mushy." But he believes that existing within that mushiness is a degree of flexibility that will be a benefit
to regulated MS4s when implementing an effective program.
Controversy Unfolds
Toward the latter part of 2008, a flurry of misinformation raced around numerous media outlets proclaiming that
residential car washing would be banned in the state of Washington. Many people were incensed that govemment
agencies would outlaw the washing of vehicles on private property.
Reacting to the firestorm, the DOE launched a full court press to set the record straight. In September alone, the DOE
issued several news releases, a fact sheet, a guidance document to cities and counties, and a two -page letter from
director Jay Manning explaining that the act of residential car washing would not, and should not, be banned.
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Photo: Daniel Smith
Water sample from a local charity car wash
nonpoint discharges) can be highly variable
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Although most of the DOE communiques listed the harmful
constituents of residential car washwater such as soaps, oils,
greases, toxic metals, and other chemicals that pollute the water
and harm fish, the agency began recommending to local
jurisdictions the following compliance path: Take the education
road first in efforts to change behavior and improve surface water
quality.
Sandy Howard, communications manager with the DOE's Water
Quality and Environmental Assessment Programs, acknowledges
that this is where the agency decided to land, and admits that it will
be up to each permitted entity to decide how hard of a compliance
line it needs to draw in order to eliminate or reduce the prohibited
discharges to "insignificant" levels.
"People have to want to do the right thing, but often times they
simply don't know what to do," she says. "It's a challenge to
change people's behaviors, but we have to help them understand
that storm drains lead to surface water with little or no treatment. First, we have to get through this leaming phase."
Sampling Design
In most cases, attempting to sample and quantify stormwater contaminants generated by common residential activities
can be daunting. These elusive constituents, which are invisible to the naked eye, include fertilizers, herbicides, and
pesticides dissolved in surface runoff from lawns and bacterial loadings produced by poor pet waste management
practices. Depending on the frequency and volume of stormwater flows, concentrations of these pollutants (the classic
Conversely, car washwater streaming into our neighborhood stormwater structures presents a more simplified sampling
opportunity. Like low- hanging fruit, it offers a much easier target to examine: the flow stream is often foamy and visible, it
can be readily captured as it drops into a catch basin, the concentration of contaminants is relatively consistent, the
discharges occur predictably on nice days, and the transport of pollutants generated by the activity is not dependant upon
fluctuating stormwater runoff.
In its own way, residential car washwater itself could be considered a point- source discharge to the MS4. But sampling
many individual driveway or street locations around the city in an effort to examine the issue would be difficult with
respect to timing, coordination, and potentially uneasy interactions with the public.
Instead, car washwater generated at several fundraising events was sampled by city staff in an effort to replicate
discharges generated by residential washing activities. Specifically, the study utilized car washwater from five distinct
weekend fundraising events in the city of Federal Way during the summers of 2007 and 2008. The events were typical,
and included groups washing cars and trucks for donations at settings such as commercial business locations and church
parking lots.
Because of the large number of vehicles washed and the volume of washwater generated, event organizers were
required to install a car wash kit to divert the flow away from the stormwater system. The kit, supplied by the city at no
cost, includes power cords, hoses, a small submersible pump, and a plastic insert that fits into catch basin structures that
receive the soapy flow.
All water flowing across the pavement in the car washing area was
collected within the catch basin insert. Collected car washwater
was pumped through a hose to a sanitary clean -out, to a sanitary
sewer manhole, or to pervious areas on site. By means of this
setup, discrete grab samples of the washwater were easily
retrieved from the car wash kit discharge hose during the midpoint
of each scheduled event.
Laboratory guidance was used to determine the number and type
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Photo: Daniel Smith
Sampling setup at the charity car wash
There are many other specific chemicals that we did not test for, but that a more comprehensive study would have
evaluated. These compounds — degreasers, metal brighteners, waxes, and other potentially toxic components —are more
extensively addressed by recent studies investigating the overall aquatic toxicity of car wash effluent and synthetic
detergents (Abel 2006 and Brasino et al. 2007).
The estimated annual pollutant loadings to the city's MS4, shown in Table 1, were calculated by converting sample
concentrations to mass and then multiplying by the estimated number of residential car washings carried out in Federal
Way over the course of a year. Our goal is to fashion the study results in a simple and meaningful way that will be
presented to residents in future public education campaigns
of sample containers used, the correct sample volume, and the
proper sample preservatives required for each parameter
analyzed. The samples were immediately chilled in a cooler, stored
in a refrigerator, and delivered to Test America Laboratories in Fife,
WA. Chain -of- custody was maintained throughout the process.
Results
The EPA notes that washwater generated from outdoor car
washing may contain many types of contaminants, including large
amounts of petroleum hydrocarbons, heavy metals, and nutrients.
In addition, data provided by the International Carwash Association
(ICA) representing wastewater discharged to publicly owned
treatment works from various commercial facilities indicate a
similar inventory of pollutants generated by car washing activity
(ICA 2002).
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Based on this information, a list of parameters to be analyzed was
developed. The parameters tested are shown in Table 1. The
following presents a brief description of the general pollutant
categories that were selected to be tested for this study:
Petroleum hydrocarbons (gasoline, diesel fuel, motor oil, fluids, and lubricants)
from automobile engines, leaks, and fuel combustion processes
Heavy metals resulting from normal wear of auto brake linings (copper), tires,
exhaust, and fluid leaks
Phosphorous- and nitrogen - containing detergents contained in wash water from
leaning vehicles (nutrient loading)
Surfactants in detergents and cleaning formulations (both synthetic and organic
agents) that lower the surface tension of water, allowing dirt or grease to be
washed off of cars
Solids washed from vehicle exteriors and impervious surfaces
gi
We used the following assumptions and conversion factors to estimate annual pollutant loadings delivered to the MS4 by
residential car- washing activities:
An estimated 62,000 passenger cars and trucks are registered in Federal Way (VVDOL 2009).
Thirty-eight percent of car owners wash their cars in the driveway (ICA 2005).
Contaminant loadings were calculated from an estimate of the annual number of residential car washes performed in Federal Way that drain to the
MS4. The final loading figures were based in part upon data presented in a study of Puget Sound area car wash behaviors (Hardwick 1997). (See
note.)
Twenty gallons is the average amount of water used to wash a vehicle (based upon field observations and simulations using a low -flow nozzle).
Eighty percent of driveway car washwater drains directly to the MS4.
The average weight of used motor oil is 7.0 lb/gal (USEPA 1993).
The average weight of gasoline is 6.1 lb/gal (USDOE 2009).
The average weight of #2 diesel fuel is 7.0 lb/gal (USDOE 2009).
The weight of ammonia is 5.15 lb/gal at 60 °F (USDOL 2009).
The following is a brief discussion concerning several of the crucial pollutants detected, including their impacts to the
city's stormwater system and their potential effects on downstream water quality:
Approximately 190 gallons of petroleum hydrocarbon waste (gasoline, diesel, and motor oil). Compounds in petroleum
hydrocarbons are highly toxic, and, in the surface water environment, they can cause harm to wildlife through direct
physical contact, contamination by ingestion, and the destruction of food sources and habitats.
Bottom - dwelling or bottom - feeding aquatic organisms may ingest
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Photo: Washington Department of Ecology
Trying to change public attitudes and behavior
phytoplankton, the base of the aquatic food chain (NRC 2008).
petroleum contaminants and transmit them up through the food
chain until they accumulate in dangerous concentrations in fish.
Hydrocarbons also harm fish directly, and damaged fish eggs may
not develop properly (USEPA 2003). Additionally, oil can be
particularly problematic because a single spilled cup can
contaminate the surface area of a waterbody the size of a football
field (USEPA 2003).
Approximately 14 pounds of dissolved copper. Exposure to
dissolved copper may be sufficient to impair the sensory biology
(olfactory system) of coho salmon (Oncorhynchus kisutch), listed
as a Species of Concem under the Endangered Species Act. Coho
and other salmonids rely on their sense of smell for critical
behaviors such as homing, foraging, and predator avoidance.
Sublethal impacts on olfactory function may reduce the chances of
survival or reproduction of individual salmon and, therefore, are a
concem for the survival of salmon populations within the Pacific
Northwest (Baldwin et al. 2003). Dissolved copper is also toxic to
Almost 400 pounds of nutrients (phosphorous and nitrogen). An increase in nutrient loading to a surface water body leads
to excessive plant growth and decay. This creates low dissolved oxygen levels, changes in animal populations, and an
overall degradation of water quality and aquatic habitat. This process is known as eutrophication. In the 2008 water
quality assessment, DOE found numerous locations in South Puget Sound impaired due to a lack of dissolved oxygen
caused by excess sources of nitrogen from human - related pollution.
Nutrient availability also impacts the formation of hazardous algal blooms (HABs), which can produce high concentrations
of nerve or liver toxins in the water column at levels that pose human health concerns (WDOE 2009a). HABs in
Washington ponds, lakes, and reservoirs (including Federal Way) have been documented at an increasing rate over the
past 25 years (WDOH 2008).
Approximately 60 pounds of ammonia. Forms of nitrogen (ammonium), in combination with pH and temperature
variations, can be toxic to fish. When this toxic combination occurs, large amounts of oxygen in the water are consumed,
subsequently stressing or killing fish and other aquatic organisms (King County 2009)
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Approximately 2,200 pounds of surfactants. In surface water environments, surfactants are acutely toxic to aquatic life,
stripping fish gills of natural oils, thereby interrupting the normal transfer of oxygen.
Approximately 34,000 pounds of solids. Sediment, the most common pollutant in stormwater runoff by volume and
weight, makes streams and lakes less suitable for fish life, plant growth, and human recreation. Sediment is of particular
concern in fish- bearing streams, where it can smother trout and salmon eggs, destroy habitat for insects (a food source
for fish), and cover prime spawning areas. Uncontrolled sediment can also clog storm drains, leading to increased private
and public maintenance costs and flooding problems
(King County 2009).
The results of this study are consistent with the findings of the Puget Sound Partnership 2008 Action Agenda declaring
that pollution - related water quality problems in the freshwaters and marine waters of Puget Sound include excess
nutrients and contamination by toxic chemicals draining from urban areas. The Action Agenda also points out that
pollution entering Puget Sound's rivers, lakes, and marine waters does so through a variety of pathways, and that surface
water runoff appears to be the primary transportation route, with the most concentrated Toads coming from developed
lands.
Given both the nature and concentration of the pollutants found in the car washwater tested, it is apparent that significant
volumes of stormwater contaminants are generated annually from residential car washing activity in Federal Way.
Stormwater carries these pollutants —soapy water and all —to storm drains in urban areas. The runoff then flows to
surface waters with little or no water - quality treatment (WDOE 2009b). This study demonstrates that any standalone
uncontrolled residential car wash might be considered inconsequential with respect to its contribution to the pollutant load
being delivered to the MS4; however, when extrapolated over the entire city of Federal Way for a year, the pollutant
loading becomes more significant.
As Will Appleton, surface water manager for Federal Way puts it, "It is akin to death by a thousand cuts. As a jurisdiction,
we tend to focus on the big bleeders, but we are finding that only a holistic approach to water quality will work." He
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continues, "Our hope is that the community will help to apply the smaller Band - Aids."
Changing Behavior
Stormwater professionals have long known the general water - quality threats posed by residential car washing runoff. To
counter these threats, environmental educators have utilized for many years both literature and advertising campaigns in
attempts to change attitudes and affect behavior.
One iconic and timeless stormwater education effort features a photo of a nerdy guy decked out in tight, checkered
shorts, black dress shoes, and black socks. Busy foaming up his late model Rambler, the man and his auto miraculously
float on the surface of Puget Sound, illustrating the connection between one's actions and nonpoint - source water
pollution.
ci
The original printed product was developed more than 10 years ago through collaboration between various public
agencies (Washington Department of Ecology, King County, and the cities of Seattle, Tacoma, and Bellevue). Still a
powerful image, the print has made its way across the nation, with electronic versions currently found posted on
municipal Web pages from Springfield, OR, to West Chester County, NY.
rage t or 0
But are these efforts effective? In reviewing car - washing attitudes and habits contained in a series of surveys conducted
by the ICA from 1999 to 2008, it appears that there is still work to do. Even though professional car- washing facilities
employ water treatment systems and in many cases recycle the wastewater, the surveys indicate that the majority of
home washers consistently feel that residential car washing is better for the environment than commercial car washes
(ICA 2008).
Future Work
Residential car washing is certainly a hot -button issue that has evolved into a conundrum for entities trying to walk the
tightrope between public discontent, permit compliance, and the preservation of our natural resources. The city of Federal
Way recognizes the challenges average homeowners face as they struggle to implement car wash stormwater pollution
prevention best management practices in their own driveways or neighborhood streets.
For starters, physical design limitations associated with a typical single - family development property may make it nearly
impossible to effectively collect and pump the dirty water to a sanitary sewer. Options for onsite infiltration may not be
available, as either gravel or grassy areas are usually not large enough on which to park a vehicle.
Much more difficult to address are less- tangible issues: the ingrained behaviors and attitudes that cause folks to choose
residential car washing when there are other, more environmentally sound, alternatives.
Solving these challenges becomes more urgent when considering the population growth trends developed for
Washington's 10 central Puget Sound counties. Currently, approximately 4.2 million people reside here, but the figure is
expected to swell 1.3 million more by 2020 (WSOFM 2009). These census predictions show us how powerful and
effective incremental behavioral changes by people can be, and how small change —when they benefit the
environment --can translate into larger and more geographically significant water - quality improvements.
The good news is that other survey data indicate people will act more environmentally responsible as more accurate
information is attained (NEETF 2005). Our public education program continues to embrace this concept and will follow
the DOE's lead in utilizing the results of this study to craft more meaningful, effective, and accurate educational tools that
describe the overall magnitude of stormwater pollution created by all home -based activities, including residential car
washing.
For the seasoned stormwater professional, the data presented in this study may not be surprising. But for average
residents, we hope that the amount of car washing contamination produced in their own community will be worrisome,
causing them to be further concerned by the prospects of pollutant loadings to our local salmon streams and Puget
Sound when the sum of discharges from the entire westem Washington region are considered.
Topics: Pollutants, Regulatory issues, Water - quality monitoring
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