Environmental Law for Pressure Washers - The Clean Water Act - What the heck is it?

[Tony Shelton]

I'm going to start a series here doing my best to put all that legal mumbo jumbo we've seen screens and screens of into simple language that everyone except for some garage cleaners can understand.



I've heard a lot of misinformation tossed around about the Clean Water Act or CWA. I see uninformed posts and documents all the time that say "The Clean Water Act says this...." or "The Clean Water Act says that...".

Most people who are saying this are simply quoting some misinformation they've read from someone else. It gets worse as it goes down the line like that experiment where each person whispers in the ear of the next.

In the late 60's and early 70's our waterways were a mess. Large companies including our own sewer treatment plants were dumping refuse and raw sewage directly into the waterways.

Something had to be done and congress adopted the Clean Water Act.

The act set up a system of regulations for who can dump into the waterways. Contrary to popular belief, the Clean Water Act in no way outlawed all dumping into the waterways! It simply set up a system to monitor and limit what can and can't be dumped into the waterways.

It has evolved a little over time. Some of the confusion comes because most people don't understand that the Clean Water Act, like most acts of Congress, just sets up a goal and then leaves it up to regulators to make up the rules and laws to conform to that goal. That is common in acts of Congress.

Fast forward to now.

Permits that allow for some discharge into the waterways are called NPDES Permits. Whoever holds an NPDES permit has "permission" (thus PERMIT) to discharge xxxx amount of waste into the "waters of the US". Permit holders are monitored and expected to work within the parameters set by the federal regulators who enforce violations with warnings, and/or fines.

I will get into NPDES permits more in another thread.

Initially the Clean Water Act was put in place to deal with the extremely large amounts of pollution that was coming from municipalities (cities, like their sewer systems) and large industries.

By the late 1990's the CWA had pretty much done it's original job. Waterways were cleaned up and industry and cities were under control and had developed BMPs or best management practices, that had worked wonders in cleaning up our waterways.

Even with the bulk of the job complete the CWA is still the law of the land. It still works to monitor discharges from NPDES holders.

No where in the CWA does the phrase "nothing down the dr@in but r@in" exist. This is a made up phrase that upon searching the internet on a date based search I found the earliest instance of its use was on Delco's DC1 website in the 90's. That website has since been removed from the internet.

Nowhere in the CWA does it address issues like runoff from mobile pressure washers.

There are, however, many laws and regulations that have come to address our industry in different municipalities in an effort to "regulate" discharges into the waters. I'll get into those more in later threads.

If you guys have any questions or if there are any officials out there who would like to add to the discussion or express anywhere I'm wrong about this simple explanation of the CWA please do so. We are all here to learn.

[Tony Shelton]

I realize I went on with too many run-on sentences.

Here is a more simplified version:

Congress made the CWA to limit the amount of waste industries and cities can dump into the waterways.

The CWA sets up a system of giving permits to dump into the waterways and limits the amounts.

Regulators were given the task to implement the law.

The CWA is not a list of rules for industries like powerwashers.

The rules come from regulators who determine the best way to implement the laws.

I hope that's better.

[Igor Zaric]

Thank you Tony ! I bet this will help our contractors to understand there are simple rules that needs to be followed and there is no "rocket science" to do it properly and stay in compliance with Federal and State regulations. It's all about education. Thanks for get this ball rolling...
Guys, feel free to ask questions...

[Chris Chappell]

Thanks for showing real truth of the clean water act.

There are many that want to try to keep it unknown so they can use that to their own agenda.

I wish every pressure washing contractor in the country would read these threads on the UAMCC site so they will be correctly informed instead of mis-informed by others out there with their agendas.

Thanks Tony!

[Kristopher Pettitt]

Clean Water Act

The 1972 amendments to the Federal Water Pollution Control Act (known as the Clean Water Act or CWA) provide the statutory basis for the NPDES permit program and the basic structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES program.


The CWA gives EPA the authority to set effluent limits on an industry-wide (technology-based) basis and on a water-quality basis that ensure protection of the receiving water. The CWA requires anyone who wants to discharge pollutants to first obtain an NPDES permit, or else that discharge will be considered illegal.


The CWA allowed EPA to authorize the NPDES Permit Program to state governments, enabling states to perform many of the permitting, administrative, and enforcement aspects of the NPDES Program. In states that have been authorized to implement CWA programs, EPA still retains oversight responsibilities.


The key sections of the CWA that directly relate to the NPDES Permit Program include:


Title I - Research and Related Programs

• Section 101 - Declaration of Goals and Policy

Title II - Grants for the Construction of Treatment Works


Title III - Standards and Enforcement

• Section 301 - Effluent Standards
• Section 302 - Water Quality-Related Effluent Limitations
• Section 303 - Water Quality Standards and Implementation Plans
• Section 304 - Information and Guidelines [Effluent]
• Section 305 - Water Quality Inventory
• Section 307 - Toxic and Pretreatment Effluent Standards

Title IV - Permits and Licenses

• Section 402 - National Pollutant Discharge Elimination System
• Section 405 - Disposal of Sewage Sludge

Title V - General Provisions

• Section 510 - State Authority
• Section 518 - Indian Tribes

[Kristopher Pettitt]

It's pretty simple to understand why The CWA was made. To clean up our waters.

[Chris Chappell]

Another way to think about the CWA is that it was meant for the huge companies, corporations and municipalities that were dumping hundreds or thousands of gallons of liquids into the bodies of water per minute, not per day, week or month.

When you compare this to most guys out there pressure washing with 8gpm or 5.5gpm or even with 2 or more machines, the difference is huge compared to big businesses or municipalities.

I was talking to our water guy when putting in a bid a month ago and the average water consumption for my city (population is 275254 I think) was anywhere from 92,000,000 gallons per day to 135,000,000 gallons per day. I did not ask because I don't think he had the waste water numbers of how many gallons of effluent water (stuff that goes to waste water, filter out the crap and other trash and then processed and treated) goes out into our bay on a daily basis.

Something I learned in Geology class in a field trip is that by federal law when the municipality is at 80% capacity or more, they can dump a huge % of untreated effluent (filtered, trash removed but not treated 100% like normal effluent) into the bay at any time they need to. This is one of many, many reasons I don't go into the bay water, tell everyone I know to not go in there or go fishing in that part of the water in this area.

When you think that maybe 1/4 of the water people use end up in the waste water system (not sure of actual numbers but since we are in a 100 year drought, not everyone can water their lawns like they used to) I am guessing that 1/4 of the water people use now ends up in waste water, that would be at least 23,000,000 gallons per day possibly or more going into the bay after it is filtered and treated.

That comes to 958,333.333 gallons per hour or 15,972.222 gallons per minute that can be dumped into the bay every minute. I don't think it works that way, I think that they reach a certain level in tanks and then dump a lot all at once but this shows you in comparison to pressure washing how insignificant we really are compared to a city we live in and how much effluent water is dumped in the local bay.

When you look at those huge numbers, the 5.5gpm or 8gpm will never reach the bay if it did hit the storm water drains as most of the piping is miles and miles long and you would have to be working all day long for even a small percentage of that water to ever reach the bay if you did send it down the storm water drain.

When you think realistically, in a drought or just summer time, those pipes are empty and usually have some trash and dirt in them from just the wind blowing (we are the 4th windiest city here in Texas) so there will always be dirt, sand and trash in the storm water drains so that is more stuff to absorb wash water (if you were to send water into the storm water drains) and the diameter of most of the storm water drains is 36" diameter up to the new piping that is going in all over town that is 6' or 8' square concrete blocks making up a new drain system (I forgot how big those concrete blocks are but they are huge) so now it takes even more water to even start puddles in these pipes and then to saturate the dirt/sand/trash in the pipes to make water to move toward the bay takes even more water to do so.

Now you are talking hundreds and hundreds of gallons of water just to start water flowing in the pipes toward the bay via storm water drains. Not sure about you but not too many jobs I do take that long, that are anywhere close to storm water drains (everyone knows about Ron teaching everyone here about dry wells) on commercial properties as it is a federal law since 1986 so there is hardly any chance for any wash water to make it anywhere close to the bay, let alone get wash water into the bay if you were dumping into the storm water drains.

When you think about this logically and understand how much water needs to be in the pipes (remember the pipes are dry because of the South Texas Heat plus the 100 year drought we are in) just for wash water to start moving towards the bay, you will still have water evaporating in the pipes as they are warm to hot just sitting there under the roads that are hot from the daytime sun so it takes even more water to get close to the bay if you were to be dumping into the storm water drains. So realistically, if you were washing in town, you would have to have many rigs running all day long to maybe have any water reach the bay if any made it there at all due to the evaporation and absorption at the jobsite, amount needed to saturate the pipes for water to start flowing and continuous evaporation in the pipes along the way, it makes no sense to think that pressure washing is polluting anything anywhere as we are cleaning up areas to keep more dirt/trash/debris from entering the storm water system as it is.

Then you have the stupidity of the "hot water is an emulsifier" nonsense that someone out there is spewing out trying to make regulations more strict. This is not mentioned anywhere in the Clean Water Act as if it was anywhere to be even remotely true, the specialists back then would have put it in the CWA so everyone would know that hot water washing is so detrimental but this is another false notion that someone out there is trying to get people to believe in to make things harder for us as contractors.

Another stupid thing is that "Hot water will kill marine life" nonsense, more stupidity and nonsense. Think about it, think about how much water it would take just to reach the bay via storm water pipes, after they are saturated so water will flow after leaving the property, after the property absorbs a lot of the water and a lot of water evaporates, how much hot water will ever reach the bay? ? ? Not a drop as water is cooling after it leaves the hot water coil, slowly cooling but still cooling.

Add to this the ambient temperature of the concrete you are washing, the concrete absorbs a lot of heat from the hot water and absorbs more as the water runs down away from where you are washing, the ambient temperature of the surfaces is absorbing the heat of the water plus the temperature outside is cooling it plus if any wind is blowing, that is helping cool it a little bit as well.

To be an idiot and think that the hot water will stay hot in miles and miles of underground piping with no insulation is just idiotic to say the least. That is like saying a hot cup of tea is going to stay hot all day long and into the nite because it started off hot. There are many factors here like the ambient temperature of the surface the water is on, traveling on, water being absorbed into the surface, water evaporating on the jobsite, water contacting pipes and releasing more heat, wind blowing thus cooling down water some as it travels, the amount of water needed to saturate the pipes before it can start moving, the amount of water to saturate the dirt/sand/trash inside the pipes before it can travel more, etc.....So much would have to be done before the water can even move inside the pipes and then now expecting hot water to stay hot for a long time, traveling over ambient temperature surfaces with wind blowing on the water and surfaces, etc.... It is just stupid in so many ways to think that any hot water would ever reach the bay is just very ignorant and stupid as I cannot find other words to describe this level of intelligence.

Even if you had insulated pipes, there would be a loss in heat along the way and it would be cool by the time it reached the bay if it ever did get there. Even if you had "Top Secret Alien Technology" insulation for the pipes, unless you had steam tracing on the pipes to keep them hot the whole way, the water would still get there cool if it ever got there due to the many factors repeated over and over (for the stupid people that think the water will stay hot the whole time and have never had a hot cup of tea or coffee sit on the counter for a while and experienced it cooling down on it's own, yes it is a miracle how that happens to some people out there but to the rest of us, it is called heat loss, cooling down, heat exchange or many other words to describe this normal thing but to some, it is a miracle and needs to be on tv, internet and many videos on youtube to share with the world) so people out there with no clue or intelligence will understand how hot water will not stay hot forever and will not travel miles and miles in pipes when doing most jobs out there.

Hope I did not type too much but sometimes I am passionate about things like this as there are many stupid people with agendas out there trying to hurt our way of life.

[Tony Shelton]

Another way to think about the CWA is that it was meant for the huge companies, corporations and municipalities that were dumping hundreds or thousands of gallons of liquids into the bodies of water per minute, not per day, week or month.

When you compare this to most guys out there pressure washing with 8gpm or 5.5gpm or even with 2 or more machines, the difference is huge compared to big businesses or municipalities.

I was talking to our water guy when putting in a bid a month ago and the average water consumption for my city (population is 275254 I think) was anywhere from 92,000,000 gallons per day to 135,000,000 gallons per day. I did not ask because I don't think he had the waste water numbers of how many gallons of effluent water (stuff that goes to waste water, filter out the crap and other trash and then processed and treated) goes out into our bay on a daily basis.

Something I learned in Geology class in a field trip is that by federal law when the municipality is at 80% capacity or more, they can dump a huge % of untreated effluent (filtered, trash removed but not treated 100% like normal effluent) into the bay at any time they need to. This is one of many, many reasons I don't go into the bay water, tell everyone I know to not go in there or go fishing in that part of the water in this area.

When you think that maybe 1/4 of the water people use end up in the waste water system (not sure of actual numbers but since we are in a 100 year drought, not everyone can water their lawns like they used to) I am guessing that 1/4 of the water people use now ends up in waste water, that would be at least 23,000,000 gallons per day possibly or more going into the bay after it is filtered and treated.

That comes to 958,333.333 gallons per hour or 15,972.222 gallons per minute that can be dumped into the bay every minute. I don't think it works that way, I think that they reach a certain level in tanks and then dump a lot all at once but this shows you in comparison to pressure washing how insignificant we really are compared to a city we live in and how much effluent water is dumped in the local bay.

When you look at those huge numbers, the 5.5gpm or 8gpm will never reach the bay if it did hit the storm water drains as most of the piping is miles and miles long and you would have to be working all day long for even a small percentage of that water to ever reach the bay if you did send it down the storm water drain.

When you think realistically, in a drought or just summer time, those pipes are empty and usually have some trash and dirt in them from just the wind blowing (we are the 4th windiest city here in Texas) so there will always be dirt, sand and trash in the storm water drains so that is more stuff to absorb wash water (if you were to send water into the storm water drains) and the diameter of most of the storm water drains is 36" diameter up to the new piping that is going in all over town that is 6' or 8' square concrete blocks making up a new drain system (I forgot how big those concrete blocks are but they are huge) so now it takes even more water to even start puddles in these pipes and then to saturate the dirt/sand/trash in the pipes to make water to move toward the bay takes even more water to do so.

Now you are talking hundreds and hundreds of gallons of water just to start water flowing in the pipes toward the bay via storm water drains. Not sure about you but not too many jobs I do take that long, that are anywhere close to storm water drains (everyone knows about Ron teaching everyone here about dry wells) on commercial properties as it is a federal law since 1986 so there is hardly any chance for any wash water to make it anywhere close to the bay, let alone get wash water into the bay if you were dumping into the storm water drains.

When you think about this logically and understand how much water needs to be in the pipes (remember the pipes are dry because of the South Texas Heat plus the 100 year drought we are in) just for wash water to start moving towards the bay, you will still have water evaporating in the pipes as they are warm to hot just sitting there under the roads that are hot from the daytime sun so it takes even more water to get close to the bay if you were to be dumping into the storm water drains. So realistically, if you were washing in town, you would have to have many rigs running all day long to maybe have any water reach the bay if any made it there at all due to the evaporation and absorption at the jobsite, amount needed to saturate the pipes for water to start flowing and continuous evaporation in the pipes along the way, it makes no sense to think that pressure washing is polluting anything anywhere as we are cleaning up areas to keep more dirt/trash/debris from entering the storm water system as it is.

Then you have the stupidity of the "hot water is an emulsifier" nonsense that someone out there is spewing out trying to make regulations more strict. This is not mentioned anywhere in the Clean Water Act as if it was anywhere to be even remotely true, the specialists back then would have put it in the CWA so everyone would know that hot water washing is so detrimental but this is another false notion that someone out there is trying to get people to believe in to make things harder for us as contractors.

Another stupid thing is that "Hot water will kill marine life" nonsense, more stupidity and nonsense. Think about it, think about how much water it would take just to reach the bay via storm water pipes, after they are saturated so water will flow after leaving the property, after the property absorbs a lot of the water and a lot of water evaporates, how much hot water will ever reach the bay? ? ? Not a drop as water is cooling after it leaves the hot water coil, slowly cooling but still cooling.

Add to this the ambient temperature of the concrete you are washing, the concrete absorbs a lot of heat from the hot water and absorbs more as the water runs down away from where you are washing, the ambient temperature of the surfaces is absorbing the heat of the water plus the temperature outside is cooling it plus if any wind is blowing, that is helping cool it a little bit as well.

To be an idiot and think that the hot water will stay hot in miles and miles of underground piping with no insulation is just idiotic to say the least. That is like saying a hot cup of tea is going to stay hot all day long and into the nite because it started off hot. There are many factors here like the ambient temperature of the surface the water is on, traveling on, water being absorbed into the surface, water evaporating on the jobsite, water contacting pipes and releasing more heat, wind blowing thus cooling down water some as it travels, the amount of water needed to saturate the pipes before it can start moving, the amount of water to saturate the dirt/sand/trash inside the pipes before it can travel more, etc.....So much would have to be done before the water can even move inside the pipes and then now expecting hot water to stay hot for a long time, traveling over ambient temperature surfaces with wind blowing on the water and surfaces, etc.... It is just stupid in so many ways to think that any hot water would ever reach the bay is just very ignorant and stupid as I cannot find other words to describe this level of intelligence.

Even if you had insulated pipes, there would be a loss in heat along the way and it would be cool by the time it reached the bay if it ever did get there. Even if you had "Top Secret Alien Technology" insulation for the pipes, unless you had steam tracing on the pipes to keep them hot the whole way, the water would still get there cool if it ever got there due to the many factors repeated over and over (for the stupid people that think the water will stay hot the whole time and have never had a hot cup of tea or coffee sit on the counter for a while and experienced it cooling down on it's own, yes it is a miracle how that happens to some people out there but to the rest of us, it is called heat loss, cooling down, heat exchange or many other words to describe this normal thing but to some, it is a miracle and needs to be on tv, internet and many videos on youtube to share with the world) so people out there with no clue or intelligence will understand how hot water will not stay hot forever and will not travel miles and miles in pipes when doing most jobs out there.

Hope I did not type too much but sometimes I am passionate about things like this as there are many stupid people with agendas out there trying to hurt our way of life.

Good post Chris!

Sent from my DROID RAZR HD using Tapatalk 2

[Tony Shelton]

Clean Water Act

The 1972 amendments to the Federal Water Pollution Control Act (known as the Clean Water Act or CWA) provide the statutory basis for the NPDES permit program and the basic structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES program.


The CWA gives EPA the authority to set effluent limits on an industry-wide (technology-based) basis and on a water-quality basis that ensure protection of the receiving water. The CWA requires anyone who wants to discharge pollutants to first obtain an NPDES permit, or else that discharge will be considered illegal.


The CWA allowed EPA to authorize the NPDES Permit Program to state governments, enabling states to perform many of the permitting, administrative, and enforcement aspects of the NPDES Program. In states that have been authorized to implement CWA programs, EPA still retains oversight responsibilities.


The key sections of the CWA that directly relate to the NPDES Permit Program include:


Title I - Research and Related Programs

• Section 101 - Declaration of Goals and Policy

Title II - Grants for the Construction of Treatment Works


Title III - Standards and Enforcement

• Section 301 - Effluent Standards
• Section 302 - Water Quality-Related Effluent Limitations
• Section 303 - Water Quality Standards and Implementation Plans
• Section 304 - Information and Guidelines [Effluent]
• Section 305 - Water Quality Inventory
• Section 307 - Toxic and Pretreatment Effluent Standards

Title IV - Permits and Licenses

• Section 402 - National Pollutant Discharge Elimination System
• Section 405 - Disposal of Sewage Sludge

Title V - General Provisions

• Section 510 - State Authority
• Section 518 - Indian Tribes

That is exactly what I was trying to say.

Sent from my DROID RAZR HD using Tapatalk 2

[Kristopher Pettitt]

The CWA was not just created for huge companies, corporations, and municipalities. It was simply a way to create law where we could clean up our national waters. Think of the CWA as the law and the EPA is the enforcement behind it. Sure that the bigger companies were dumping more, but that doesn't mean the little guy wasn't.

Also over a dozen little guys dumping pollution into the water is just as bad as one big company. We can all do our part to our waters clean.

It's ignorant to think that one's waste water (no matter how little you may think it is) is insignificant. You're just adding to the million gallons of waste water and thats where the problem is.

Also its good to remember where we each live and work. There are reason why certain places have stricter enforcements than others. From reading what I have so far I've come to the realization that it is sometimes based on what waterways are nearby. If you live in the desert (per-say) the waste water will more then likely dry up, thus never reaching the waters. So you have a lesser enforcement. However if you are working near say a bay or a body of water where the city depends on the water for survival then that's when stricter enforcement are required.

Basic law here is that as one person may not be the cause of the pollution, but may be adding to it. How this applies to us as pressure washers depends greatly on where you live and what regulations are already in place. Just like laws, regulations will adapt and change. We can do our part and speak with our regulators making sure they understand what we do as pressure washers.