The Michigan Department of Environmental Quality (MDEQ) regulates discharges of wastewater to/onto the ground within the State of Michigan. Any projects at UM involving cleaning activities outside, (including but not limited to the use of cleaners, soapy water, washwaters, etc.) must perform a thorough review of the proposed management of wastewater generated by the project.
Information on cleaning / power washing activities is provided for two distinct categories of workers:
- Contractors at UM
- UM Employees ONLY
Information for Contractors at UM
Exterior Cleaning or Power Washing
Many UM projects include exterior washing operations that occur outdoors. These activities require proper management of the wastewater generated by either:
Contractor may obtain approval from the Michigan Department of Environmental Quality (MDEQ) for their company to discharge to the ground by "authorization by notification" as a mobile power washer. Additional information can be found in MDEQ’s Power Washing Guidance.
Do not allow runoff from cleaning activities that is discharged to ground to leave the site or enter any drains.
NOTE: Discharge to ground means discharge to grassy and/or soil areas capable of water infiltration. Discharge to ground cannot be utilized during frozen ground conditions, as water discharge will freeze and/or run off into storm drains. If operations will occur during winter or frozen conditions – the wash water must be collected and sampled to determine proper disposal, as identified in item 2 below.
- Collect wash water into compatible containers and sample to determine the proper disposal method. Coordinate with UM-Hazardous Materials Management (734-763-4568) for management of this waste. Allow adequate lead time for sampling, analysis and disposal activities.
**Protect storm drains and catch basins to ensure there is no discharge of wastewaters into these systems during exterior cleaning, power washing or wastewater collection activities.
Information for UM Employees ONLY
Any department engaging in outdoor washing, cleaning or power washing activities that use any additives (including soap) must contact UM-Occupational Safety and Environmental Health (OSEH) to determine if the wash water needs to be collected for proper disposal.
The Michigan Department of Environmental Quality (MDEQ) has re-issued an Authorization to Discharge (to ground), to the University of Michigan, #GW1110289, for portable power washing operations under Rule 2211(e). This approval allows wash water containing additives to drain into the surrounding ground for graffiti removal, cleaning of brick and stonework, and other activities as performed by UM personnel. NOTE: This authorization applies to UM staff only. Contractors must get their own authorization/permit from MDEQ.
OSEH administers the groundwater discharge authorization for the University. This includes notifications to MDEQ, auditing of discharge logs/records, and technical assistance to UM departments. OSEH-EP3 must track information from UM departments on all outdoor washing activities discharging to the ground and collect specific data from each project for reporting to MDEQ. Any University department wishing to use additives while performing outside washing operations must contact OSEH Environmental Protection & Permitting Program (EP3) a minimum of two days in advance, for approval prior to beginning work.
Each UM department must follow the requirements identified in the Authorization to Discharge #GW1110289. Detailed requirements are identified in the linked documents. General requirements for discharge from outdoor washing activities follow:
- The water source used for washing must be potable water.
- All products (additives) must be used for their intended purpose, and in accordance with the manufacturer’s recommendations and label directions.
- Washing must be limited to the removal of dirt from the exterior of a vehicle, equipment or a stationary source. Washing of the undercarriage of a vehicle or equipment is prohibited.
- Discharge to ground from washing activities is limited to 1,000 gallons per acre, per month per discharge site.
- Discharge to ground from washing activities cannot exceed 3,200 gallons per year of wash water with additives.
- A discharge log must be completed with all required information. [Note: The UM Exterior Cleaning and Power Washing Log form is linked for your use. UM departments must complete the log daily and submit it within 48-hours to OSEH-EP3 for review and tracking.] The log must be kept by the department for a minimum of 3 years and made available for inspection at any time.
Wash water with additives is prohibited from draining into the University’s stormwater drainage system. Before starting any outside washing operations, all building footer drains and storm drains within the cleaning area must be covered. All storm drains in and adjacent to the work area must be blocked to prevent contaminants from draining to the river. If no additives are used, all storm drains adjacent to the work area must have filter fabric or sediment control sacks installed to prevent sediment from draining to the river. If power washing will occur in areas that have water wells or monitoring wells, the wells must be protected to prevent seepage from the wash water.
Also note that washing some surfaces can potentially produce hazardous waste. Contact OSEH before starting washing operations on painted or treated surfaces. Examples of these washing activities include stripping old paint from buildings or degreasing equipment with solvents and spraying them clean. This wastewater must be collected and placed in proper containers for disposal by OSEH or an OSEH-approved contractor. If the work is determined to produce a hazardous waste, consider using alternative products or methods to reduce the amount of waste generated.
Contact OSEH-EP3 (734-936-1920) to review the proposed outdoor cleaning activities, or for information on applications to obtain authorization for discharge to the ground from MDEQ.
Contact OSEH-Hazardous Materials Management (734-763-4568) for collection of wastewaters and disposal off site.