tomtucson
New member
Point #7
The PWNA Bmps can be found here under 2011 PWNA Cosmetic Cleaning BMPS:
I don't want to copy and paste the entire text because of the copyright warnings they have plastered all over it.
http://www.thepwna.org/water_reclaimer.php
The first thing of note is the heading:
PWNA &UAMCC’s Cosmetic Cleaning
Best Management Practices
This is still being represented as BMPs for the UAMCC even after Robert was removed at environmental director for doing just that.
Under "Clean Water Act" there is this telling sentence, that is a true statement, but is not even addressed under any of the practices as being a proper way of compliance:
• If your discharge does not reach the waters of the United States, then there are no requirements under the Clean Water Act.
Under "Always filter wash water before discharging we have the first requirement that is over and above most jurisdictional requirements. This is the first limitation on our ability to make our own choices based on the situation at hand and removes the ability to use hay bale style berms like the construction industry:
• Remove silt, sand, sludge, debris, etc. by filtering through a 20 mesh screen or smaller.
Under "Wash Water Capture" we again, add regulations that currently do not exist with the EPA. Further, the phrase "on a surface that will not absorb contaminants is ambiguous and could very well serve as an impediment towards discharging into a vegetative area in the future. This is in direct contrast with the statement above about "no requirements" if it doesn't leave the property.
• 4th Choice - Evaporation is acceptable as long as the evaporation occurs on property and on a surface that will not absorb contaminants. After the surface has dried the contaminants need to be swept or vacuumed up so that when it rains the contamination will not be washed away.
Under "Discharge to the sanitary sewer" - Here is a telling statement:
The city of Fort Worth has never been able to detect wash water from Cosmetic Cleaning in their POTW (Publicly Owned Treatment Works).
If soapy cleaning water, or captured runoff from cleaning garages has been undetectable by the city of FT Worth in their sewer, then how is it that runoff into the storm drain would make us "major offenders"? I'm just curious about that.
Under "Discharge to Landscape Areas 2nd choice" - This is another arbitrary limitation that we are placing on ourselves.
. Limit your discharge to 1,000 gallons/acre per month.
and get ready house washers:
• Off property discharge can cause serious harm to groundwater.
-Contract cleaners that are near a body of water like San Francisco, Miami, Fort Lauderdale can contaminate ground water. Example, if building a fence in your area were to hit ground water, the water table is high and discharging would pollute the groundwater. It is important to check with your local municipality. As a general rule, the water table needs to be 50 feet down depending on your type of soil.
Under "Recycled Wash Water 3rd choice" - because of the hauling issue I'm not so certain the idea of recycling and removing from the property should even be a choice at all!!!
If the waste water is recycled long enough the pollution becomes hazardous waste. There is a continuous buildup of total dissolved solids, heavy metals, and detergents. This then requires the contractor to have a hazardous waste haulers permit.
Under "Discharge to storm drains" Not Recommended - We've already discussed this issue. In the initial BMPs Robert had nothing in there about allowing ANY washwater into the storm drains at all. I sent him BMPs from all over the place that allowed for plaza cleaning without soap to go down the storm drain with nothing but an unspecified debris mesh and he did, in fact change the BMPs to allow for it, but he added the hot water issue, effectively nullifying it since most all of us clean with hot water. It was a contrived way to outlaw any plaza cleaning that is effective (hot water) and was slipped in without much fanfare. While it is later left out, as I suggested, in "Plaza cleaning without soap", this sets a the stage for citations if adopted as is by the authorities. It is contradictory.
Also, as mentioned before, emulsification has never, ever, been an issue with the EPA. Robert Hinderliter has MADE it an issue.
• Washing with cold water (less than 110°F) and no chemicals is considered no worse than a rain event and may be discharged to Storm Drains for surfaces that do not have oil and grease or other contaminants.
• Water that is greater than 110°F is considered hot water and considered the same as using soap.
- Hot water is an emulsifier and similar to using a detergent.
Under "Discharge Limits" - This section mandates that flocked contaminants be removed by the added expense of a Waste Hauler eliminating the ability to dry out the matter and throw it in the dumpster when that option is available. This may have huge consequences in the future.
• Flocking may also be an option. Flocking is the adding of a chemical that separates and binds pollutants together so they either drop out to the bottom or float to the surface. The cleaned water can then be discharged to the Sanitary Sewer. The flocked pollutants are stored in a drum until an Environmental Waste Hauler can pick up for proper disposal
Under Drought Conditions: - I don't know why this is in here at all:
• Potable Water - depending on the drought restrictions in your area, the local potable (drinking) water supply may be restricted for power washing except for health and safety reasons.
• When power washing for health and safety reasons permission is required in advanced from the Health or Environmental Department.
Under "Transportation Related Washing" - Note, while it is well established that FLEET washing has more pollution potential than general powerwashing it is interesting to see that the 1000 gallon per month limit on directing to the landscaping is not a requirement here .This is in direct conflict with earlier paragraphs and opens us up to citations:
2nd Best - direct wash water to landscape or dirt area.
• Wash water should be discharged to a landscape or dirt area sufficiently large enough to contain all the wash water. Discuss with the property owner.
And here, evaporation is okay and again, there is no limitation on gallons per month into the landscaping. This disregards the claim that evaporated runoff must be dried and swept as outlined earlier. It makes the BMP look good to the contractor who glances through the BMP looking specifically for their own niche and doesn't read the rest. But, if codified into regulation this can quickly be pointed out that evaporation without drying and sweeping is illegal. Contradictory again.
Mobile Auto Detailing
Infrequent, light cleaning, using soap - rarely at the same site; removing mainly dirt with minimum water volume.
Preferred - minimal runoff may remain on paved surfaces to evaporate.
• If wash water will reach the Storm Drain, seal the Storm Drain and discharge the wash water to the Sanitary Sewer.
2nd Best - direct wash water to landscape or dirt area.
• Wash water should be discharged to a dirt or landscape area sufficiently large enough to contain all the wash water. Discuss with the property owner.
Under Sidewalks, Plazas, Driveways, Drive-thru Window Areas - with light oil, frequently cleaned - no soap - again this looks Reasonable and rational till you combine it with the prior hot water limit. This is again, contradictory.
• Sweep, collect and dispose of debris.
• Dry clean oil spots and properly dispose of debris.
• Place oil absorbent boom or oil sock around storm drain.
• Wash water may go to the Storm Drain through an oil absorbent boom and screen.
• No oil sheen can be visible on the water flowing into the Storm Drain.
And lastly I submit the following examples from the BMPs that prove "nothing down the drain but rain" that Robert Hinderliter keeps repeating, is a fallacy and just serves to confuse regulators:
• If the vehicle or vehicles have been previously washed with a soap or solvent following BMPs, then it is acceptable to rinse the vehicles with just water and allow to discharge to a Storm Drain.
• Wash water may go to the Storm Drain through an oil absorbent boom and screen.
• Wash water may go to the Storm Drain through an oil absorbent boom and screen.
After all of the above have been determined, you need to contact the Sanitary Sewer or Storm Drain (MS4) Departments about discharging to them through the building collection system if it exists, and determining what additional remediation may be required.
NOTHING DOWN THE DRAIN BUT RAIN is a phrase our industry should never repeat. The fact is, NPDES permit holders (usually our cities) have the permit specifically so they CAN discharge SOME things down the storm drain.
Yes, Robert Hinderliter, I have read the BMPs. You know it because I went over some of these things with you a long time ago when you put them out for our "review" and our ultimate rejection before you implemented them against our will.
I ask everyone to read them, but please read the whole thing. If you skip to your own industry it doesn't look bad at all until you realize that as a whole, the document outlaws all unreclaimed washing that is effective.
Whew! Finally done. Please feel free to ask any questions and I'll do my best to answer.
More important points here that should be addressed. Another 200 pages should do it! Is any one else feeling massive obfuscation going on?
