WASH RACKS FOR POLLUTION PREVENTION

Virtually every municipality has enacted some level of pollution prevention regulation, typically in the form of a P2 or Stormwater Pollution Prevention Plan (SWPPP).

Most SWPPP’s state that facilities that produce or need to dispose of wash water fall under the regulation of the Clean Water Act.

These include municipal, industrial and commercial facilities, including construction activities, military bases and shipping ports. Wash water comes in the form of contaminated stormwater that can potentially pollute water sources.

Federal EPA regulations set the floor. State programs frequently set higher standards, require additional permits, or define stricter discharge limits. The following snapshots cover states with particularly active enforcement or unique program requirements relevant to fleet wash operations.

California

California operates under some of the strictest stormwater requirements in the country. The Industrial General Permit (IGP) requires facilities in designated industrial categories to develop and implement a SWPPP, conduct regular monitoring, and report discharge monitoring results through the state’s SMARTS online system. Vehicle wash water from construction and fleet operations is subject to numeric action levels for turbidity, oil and grease, and pH. Several California regional water boards have issued enforcement actions specifically targeting unpermitted vehicle washing.

Michigan

Michigan’s Part 31 of the Natural Resources and Environmental Protection Act governs discharge to surface waters and stormwater systems. Road commissions and county fleet operations are subject to MS4 permit requirements in urbanized areas. Michigan also has specific rules regarding chloride discharge from road-salt operations that intersect with washwater management for winter-maintenance fleets. The Michigan DEQ has conducted targeted inspections of county road commission facilities.

Texas

Texas Commission on Environmental Quality (TCEQ) administers the Multi-Sector General Permit (MSGP) for industrial stormwater. Construction site wash water is regulated separately under the Texas Construction General Permit. Texas has a history of enforcement against unpermitted discharges from equipment yards and rental operations, particularly in the Permian Basin where oilfield equipment presents elevated contamination concerns.

Florida

Florida’s proximity to sensitive aquifers and the Everglades ecosystem creates heightened regulatory attention to wash water management. The Florida Department of Environmental Protection enforces strict standards for discharge to Class I and Class II waters. Municipal fleet operations in South Florida face additional scrutiny due to the direct hydraulic connection between stormwater systems and the Biscayne Aquifer, a primary drinking water source.

A Note on Local Authority

In most states, county and municipal environmental health departments have independent authority to regulate wash water discharge beyond state minimums. Before finalizing any wash system design, confirm local requirements with both your state environmental agency and your county or municipal public works department.

Introduction to EPA’s NPDES Stormwater Program

The following information is sourced directly from the Environmental Protection Agency (EPA) website and is intended for educational purposes. It provides an overview of the National Pollutant Discharge Elimination System (NPDES) Stormwater Program, including its scope, importance, and the problems associated with stormwater pollution.

NPDES Stormwater Program

More Information on the Stormwater Program
* [Stormwater Centers of Excellence Grants](https://www.epa.gov/npdes/stormwater-centers-excellence-grants)
* [Stormwater Planning](https://www.epa.gov/npdes/stormwater-planning)
* [Stormwater Rules and Notices](https://www.epa.gov/npdes/stormwater-rules-and-notices)
* [Stormwater Best Management Practices Fact Sheets](https://www.epa.gov/npdes/national-menu-best-management-practices-bmps-stormwater)
* [Stormwater Webcasts](https://www.epa.gov/npdes/stormwater-webcasts)

NPDES stormwater program areas:
* [Stormwater Pollutants of Emerging Concern](https://www.epa.gov/npdes/stormwater-pollutants-emerging-concern)
* [Stormwater Discharges from Construction Activities](https://www.epa.gov/npdes/stormwater-discharges-construction-activities)
* [Stormwater Discharges from Industrial Activities](https://www.epa.gov/npdes/stormwater-discharges-industrial-activities)
* [Stormwater Discharges from Municipal Sources](https://www.epa.gov/npdes/stormwater-discharges-municipal-sources)
* [Stormwater Discharges from Transportation Sources](https://www.epa.gov/npdes/stormwater-discharges-transportation-sources)
* [Oil and Gas Stormwater Permitting](https://www.epa.gov/npdes/oil-and-gas-stormwater-permitting)
* [EPA’s Residual Designation Authority](https://www.epa.gov/npdes/epas-residual-designation-authority)
* [Stormwater Maintenance](https://www.epa.gov/npdes/stormwater-maintenance)
* [Stormwater Planning](https://www.epa.gov/npdes/stormwater-planning)

Problems with Stormwater Pollution Prevention

Stormwater runoff is generated from rain and snowmelt events that flow over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. The runoff picks up pollutants like trash, chemicals, oils, and dirt/sediment that can harm our rivers, streams, lakes, and coastal waters. To protect these resources, communities, construction companies, industries, and others use stormwater controls, known as best management practices (BMPs). These BMPs filter out pollutants and/or ensure pollution prevention by controlling it at its source.

The NPDES stormwater program regulates some stormwater discharges from three potential sources: municipal separate storm sewer systems (MS4s), construction activities, and industrial activities. Operators of these sources may be required to obtain an NPDES permit before discharging stormwater. This permitting mechanism is designed to prevent stormwater runoff from washing harmful pollutants into local surface waters.

[Authorization Status for EPA’s Stormwater Construction and Industrial Programs](https://www.epa.gov/npdes/authorization-status-epas-construction-and-industrial-stormwater-programs) – Most states are authorized to implement the stormwater NPDES permitting program. EPA remains the permitting authority in a few states, territories, and on most land in Indian Country.

Population growth and the development of urban/urbanized areas are major contributors to the amount of pollutants in the runoff as well as the volume and rate of runoff from impervious surfaces. Together, they can cause changes in hydrology and water quality that result in habitat modification and loss, increased flooding, decreased aquatic biological diversity, and increased sedimentation and erosion. The benefits of effective stormwater runoff management can include:

* protection of wetlands and aquatic ecosystems,
* improved quality of receiving waterbodies,
* conservation of water resources,
* protection of public health, and
* flood control.

Traditional stormwater management approaches that rely on peak-flow storage have generally not focused on pollution prevention and can exacerbate problems associated with changes in hydrology and hydraulics.

See the following for additional information:
* [National Research Council Report on Urban Stormwater](https://www.nap.edu/catalog/12465/urban-stormwater-management-in-the-united-states)
* [National Water Quality Inventory Report to Congress (305(b) report)](https://www.epa.gov/waterdata/national-water-quality-inventory-report-congress)
* [Impaired Waters on the 303(d) List](https://www.epa.gov/tmdl/program-overview-303d-listing-impaired-waters)
* [Chapter 4 (Environmental Assessment) from EPA’s Preliminary Data Summary of Urban Stormwater Best Management Practices (1999)](https://www3.epa.gov/npdes/pubs/usw_c.pdf)