1. Mobile Washing Policy Florida Statutes Section 403.087 contain the basic requirement for DEP regulation. Must be a stationary pollution source, such as a fleet maintenance lot. Does not reference disposal of the wastewater in the Statute as a criteria. Statute requires a permit or exemption.

2. Different Types of Systems Surface Water Discharge-NPDES Ground Water Discharge: Sprayfield, Drainfield, Spray Irrigation, French Drain Recycle System-Only 100% Counts Connected to Sanitary Sewer, With the Utility’s Approval Pump and Truck Wastewater Elsewhere

3. What Does an Exemption Require? No Surface Discharge Can be Exempted. Rules Do Not Have Specific Standards for Exemptions. No Reasonable Potential for Pollution Identify a Best Management Practice-BMP Sell Your Proposal, Provide Support

4. What You Need to Know About an Exemption? No Fee No Forms No Engineer The Key Is to Present Your Site Specific Proposal On the No Reasonable Potential Basis. Worst Case?-Permit required.

5. What Are a Mobile Washer’s Obligation? Being Mobile, Vendors/Contractors Do Not Need Formal Approval Under the Statute. Your Client at a Stationary Facility Has The Obligation for Approval. Liability Remains for Violation of Surface/Ground Water Standards. The “Free Froms” Apply at All Times and Places.

6. What Are the Client’s Obligations? Either Connect to Sanitary Sewer, or Have a Service Haul the Wastewater to an Approved Disposal System, or Comply With the Statute by getting an Exemption or Permit. Yes, a Vendor/Contractor May be an Agent to Apply for the Exemption or Permit on The Facility’s Behalf.

7. What Would Prevent an Exemption Approval? Any Potential For Surface Discharge. Washing Garbage/Solid Waste Trucks. Degreasing Parts/Engines Cleaning Tankers Internally/Steaming Undercarriages Any potential Impact On/Off Site Wells/Property Use of Solvents/Strong Chemicals

8. Ok Then, A Permit Not Required for Sanitary Sewer Connection. Pretreatment Before Sanitary Sewer Connection-Still No Permit Required. If a Permit is Required, So Is a P.E. Recycle or Not to Recycle? That Is The Evaluation That the P.E. Is Paid to Make.

9. Recycle System Trade Offs Negatives: Higher Treatment Quality Needed Higher Capital Cost to Build the System Has More Maintenance Due to Complexity Wastewater Becomes “Spent”-Must Pay Hauler Waste Oil and Sludge for Disposal

10. Positive Trade Offs Application Fee Is Less: $200 vs.. $1500 on the Smaller Systems and Renewals for Half That Every 5 Years. Engineering Fees Associated With Application Are Less Due to Simple Engineering Report. No Routine Samples Required.

11. Ground Water Discharge Might Still Get an Exemption for Small Systems Based on a BMP. Land Application System: Pond, Drainfield, Sprayfield- DEP Has No Preference. Less treatment May Be Needed-Less Capital/ Easier to Maintain Does Have Sampling Unless Exempt

12. What About That Ditch Beside the Property? Should Not Be Considered Until All Other Options Have Been Rejected. Why?-Too Expensive to Meet Discharge Standards. Anti-Degradation Report. Needs a Level Of Treatment That a Small Business Cannot Afford. Continuing Tests and Toxicity Analyses

13. Isn’t That a Lot? Florida Was Given Delegation for a Federal Program May 1, 1995. Governs Surface Discharges Eliminates Exemptions for Surface Discharges-No Discretion Allowed NPDES-National Pollutant Discharge Elimination System

14. Oil-Water Separators These Are Just Another type of a Treatment Unit, Such as Filtration or Settling. Does Not Determine Permitting Requirements. Directions on Previous Slides Apply. Best Designs Have an Off-Line Holding Tank for the Waste Oil.

15. But I Already Have a Pond Out Back Most Likely That Was Designed as a Stormwater Pond. Holds Runoff From the First Inch of Rainfall, Then Discharges Off Site. Evaluate Any Potential for Discharge, If so Then NPDES Rules Apply Again. We Would Be Conservative In View.

16. It’s Just a Bit of Water, How About My Septic Tank? Septic Tanks Are Regulated by The Dept. of Health. They Have a Rule Too, Thou Shall Not Put IW Into a Septic Tank. DEP Cannot Authorize Your Use of a Septic Tank For Any IW or DW Purpose. However a Treatment System May Use the Tanks in Various Treatment Components, i.e. Settling Tank.

17. Potable Water Well Protection Carpet Wastes Must Not Be Discharged: Within 100 feet of a Public Water Supply Well (Rule 62-555 FAC). Within 75 feet of a Private water Supply Well (Dept of health Rule) Within 75 Feet of Surface Waters Where Ever Such Discharge Would Cause nuisance Conditions.

18. Who Do I Contact at DEP? For More Clarification of These Issues, Application Forms and Permitting Matters Call Ali Kazi at 407-893-3316 or Gene Elliott -3317. For Field Evaluation, Complaints or Help in Preparing Reports Call Gary Miller at 407- 893-3986 or Kalina Warren -3313.

19. County Rules In the Eight Counties Regulated by the Central District only Indian River County Does Not Have a Local Environmental Program. None Are Delegated Responsibility From the State for the IW Program. Each Local County Program May Have Regulations That Apply to Your Business. We Encourage You to Check With the County.