EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Ron Musgraves said:
John we have been Explaining to you that we have been having regulators at every Large cleaning Expo meeting since 2009.

In 2008 when Russ Launched the PWNA water reclaim program we started having them attend.

This is the primary reason most do not agree with Robert Logic, the bMP's are fine, even the hot water doesn't bother me. The wrapping paper he puts them in doesn't match what real people are telling us. Its not us that have to change anything, we need Robert to stop promoting we are polluters.

These people for the most part realize we are the solution to the problem.

The www.uamcc.org has no up hill battle for now, no one will know what the future holds. We do need to stop preaching polluters, its a poor choice and everyone can see that regardless if your a dirty Dozen or Ron lover.

Whats right is as plain as Day
Click to expand...
Show me where Robert is promoting us in your words "Polluters". I see him as given us options. You keep saying he's promoting us as polluters.. Where is that so we can get Robert to respond.
 
Clean County PW said:
Show me where Robert is promoting us in your words "Polluters". I see him as given us options. You keep saying he's promoting us as polluters.. Where is that so we can get Robert to respond.
Click to expand...
He never talks about options of containment
 
Ron Musgraves said:
He never talks about options of containment
Click to expand...

Clean Water Act


[FONT=Arial,Arial][FONT=Arial,Arial]In 1972, Congress enacted the first comprehensive national clean water legislation in response to growing concern of serious and widespread water pollution. The Clean Water Act states "no person shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the municipal separate storm sewer system (a.k.a. MS4) any pollutants or waters containing any pollutants, other than storm water". [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 The Clean Water Act administration raised the penalty for class 1 penalties to over $30,000 and class 2 penalties to over $150,000. Violations to the CWA can cost up to $11,000 a day for each day of illegal operation.

 If your discharge does not reach the waters of the United States, then there are no requirements under the Clean Water Act.


[/FONT][/FONT]Cosmetic Cleaning only


[FONT=Arial,Arial][FONT=Arial,Arial]This BMP is for regular maintenance Cosmetic Cleaning and is not for the purpose of cleaning hazardous materials or hazardous waste. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

[/FONT][/FONT]Always Pre-clean


[FONT=Arial,Arial][FONT=Arial,Arial]Before power washing begins collect debris such as dirt, sand, leaves, twigs, etc. by sweeping with a broom, using a leaf blower, or vacuum and dispose of in a trash receptacle or dumpster. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 Never discharge dirt, sand, leaves, twigs or any other solid into the Sanitary Sewer or Storm Drain.

 Before power washing begins clean oil and grease spots with an oil absorbent clay (such as kitty litter) and dispose of in a trash receptacle or dumpster.


[/FONT][/FONT]Always Filter Wash Water before Discharging


[FONT=Arial,Arial][FONT=Arial,Arial]Remove silt, sand, sludge, debris, etc. by filtering through a 20 mesh screen or smaller. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
4

[/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]- A 20 mesh screen is similar in size to traditional panty hose/nylon stockings. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 Remove hydrocarbons by filtering through an oil absorbent filter/oil sock or oil/water separator such as an oil absorbent boom, recycling system, sand trap, grease trap, clarifier, etc).


- Hydrocarbons are oil and grease pollutants.

- After the wash water is filtered, there should not be any oil sheen (multi colored water).

[/FONT][/FONT]Wash Water Capture


[FONT=Arial,Arial][FONT=Arial,Arial]1st Choice - Use a permanent pad to capture the wash water. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

- A permanent pad is typically made of concrete and is designed for washing vehicles while preventing wash water from reaching a Storm Drain.

 2nd Choice - Use a portable pad to capture the wash water.

 3rd Choice - Seal the Storm Drains and capture the wash water with a vacuum system, sump or other technology.


- The type and technology of the system is the responsibility of the contract cleaner.

 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. If the surface is a gravel or porous surface, the water table must be at such a depth where the groundwater will not be polluted. Check with your local municipality.


[/FONT][/FONT]Discharge to the Sanitary Sewer - Preferred


[FONT=Arial,Arial][FONT=Arial,Arial]Discharging to the Sanitary Sewer is allowed with a Cosmetic Cleaning permit. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

- Some cities require a permit others do not. Contact your Public Works department for your city's requirements. The Public Works department may need to direct you to another department.

 Discharge must be in compliance with local regulations and limits (Solids less than 250 mg/L, Petroleums less than 250 mg/L), and may require pre-treatment, sampling, and possibly other measures.


- This will depend on the municipality.

- The city of Fort Worth has never been able to detect wash water from Cosmetic Cleaning in their POTW (Publicly Owned Treatment Works).

 Ensure pH of the wash water is between 5.0 and 12.0 (use pH test strips) and below 150˚.


- These limits are typically above normal Cosmetic Cleaning wash water.

 Filter using the best available method that removes the largest amount of contaminants.


- Sand Trap, Grit Trap, Grease Trap or Clarifier.

- If these options are not available then discharge to a mop sink, utility sink, kitchen sink, toilet, inside floor drain, or Sanitary Sewer clean-out stub.

- Never remove the Sanitary Sewer or Storm Drain manhole cover as these are City Property and require authorization to open. 5

[/FONT][/FONT]
Discharge to Landscape Areas - 2nd Choice


[FONT=Trebuchet MS,Trebuchet MS][FONT=Trebuchet MS,Trebuchet MS]For discharges to landscape areas you must do the following: [/FONT][/FONT]
[FONT=Trebuchet MS,Trebuchet MS][FONT=Trebuchet MS,Trebuchet MS]

[/FONT][/FONT][FONT=Arial,Arial][FONT=Arial,Arial]- Obtain the property owner’s permission.

- Ensure discharge volume is small enough that it soaks into the ground without running off property. Limit your discharge to 1,000 gallons/acre per month.

 On property wash water discharge can only occur at the property where the wash water is generated.

 Do not discharge repeatedly to the same landscape area because doing so may contaminate soil and groundwater, damage plants and cause other nuisance conditions.

 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.

 Ensure pH of the wash water is between 6.0 and 9.0 by using pH test strips.


[/FONT][/FONT]Recycled Wash Water - 3rd Choice


[FONT=Arial,Arial][FONT=Arial,Arial]If the wash equipment being used recycles the water for reuse, the following may apply. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

- All discharge locations are to be reported to the Sanitary Sewer Department in advance of discharging wash water.

- Recycled wash water typically must be tested annually and the results reported to the Sanitary Sewer Department as required.

 Recycling wash water has the effect of concentrating the contaminants and pollutants. The POTW (Publicly Owned Treatment Works) do not typically accept concentrated waste water. 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.


[/FONT][/FONT]Discharge to Storm Drains - not recommended


[FONT=Arial,Arial][FONT=Arial,Arial]Never discharge detergents, chemicals, or hot water to Storm Drains. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 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.

 Discharges must be free of foam and oil sheen.


- An oil sock will remove foam and oil sheen.
[/FONT][/FONT]
 
Duplicate
 
Robert, please allow me to show you how to fight for our industry:


Robert Hinderliter said:
Clean Water Act


[FONT=Arial,Arial][FONT=Arial,Arial]In 1972, Congress enacted the first comprehensive national clean water legislation in response to growing concern of serious and widespread water pollution. The Clean Water Act states "no person shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the municipal separate storm sewer system (a.k.a. MS4) any pollutants or waters containing any pollutants, other than storm water". [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 The Clean Water Act administration raised the penalty for class 1 penalties to over $30,000 and class 2 penalties to over $150,000. Violations to the CWA can cost up to $11,000 a day for each day of illegal operation.

 If your discharge does not reach the waters of the United States, then there are no requirements under the Clean Water Act.


[/FONT][/FONT]Cosmetic Cleaning only (First of all "Cosmetic" cleaning denotes cleaning that is not necessary. "Health and Safety" cleaning or something like that denotes a necessary service.)


[FONT=Arial,Arial][FONT=Arial,Arial]This BMP is for regular maintenance CosmeticHealth and Safety Cleaning and is not for the purpose of cleaning hazardous materials or hazardous waste. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

[/FONT][/FONT]Always Pre-clean


[FONT=Arial,Arial][FONT=Arial,Arial]Before power washing begins collect debris such as dirt, sand, leaves, twigs, etc. by sweeping with a broom, using a leaf blower, or vacuum and dispose of in a trash receptacle or dumpster. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 Never discharge dirt, sand, leaves, twigs or any other solid into the Sanitary Sewer or Storm Drain.

 Before power washing begins clean oil and grease spots with an oil absorbent clay (such as kitty litter) (or any other effective method) and dispose of in a trash receptacle or dumpster.


[/FONT][/FONT]Always Filter Wash Water before Discharging


[FONT=Arial,Arial][FONT=Arial,Arial]Remove silt, sand, sludge, debris, etc. by filtering through a (purpose designed filter media or a) 20 mesh screen or smaller. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
4

[/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]- A 20 mesh screen is similar in size to traditional panty hose/nylon stockings. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]
 Remove hydrocarbons by filtering through an oil absorbent filter/oil sock or oil/water separator such as an oil absorbent boom, recycling system, sand trap, grease trap, clarifier, etc).


- Hydrocarbons are oil and grease pollutants. (Strike this whole sentence, we are not working for the EPA so we don't need to educate them on what pollutants are unless they start calling non-pollutants pollutants like they recently did with an over abundance of storm water and got shot down in federal court.)

- After the wash water is filtered, there should not be any oil sheen (multi colored water).

[/FONT][/FONT]Wash Water Capture


[FONT=Arial,Arial][FONT=Arial,Arial]1st Choice - Use a permanent pad to capture the wash water. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

- A permanent pad is typically made of concrete and is designed for washing vehicles while preventing wash water from reaching a Storm Drain.

 2nd Choice - Use a portable pad to capture the wash water.

 3rd Choice - Seal the Storm Drains and capture the wash water with a vacuum system, sump or other technology. (All of this needs to go, in this context, unless we make another heading for fleetwashing/car washing, you are confusing people with this)


- The type and technology of the system is the responsibility of the contract cleaner.

 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. If the surface is a gravel or porous surface, the water table must be at such a depth where the groundwater will not be polluted. Check with your local municipality. (More fleetwashing lingo)


[/FONT][/FONT]Discharge to the Sanitary Sewer - Preferred (This word "preferred" needs to go entirely. I know that some BMP's have such verbiage, but this just puts it in a regulators head that since one way is "preferred" why give them any other options. Especially since it is coming from one of our OWN orgs! )


[FONT=Arial,Arial][FONT=Arial,Arial]Discharging to the Sanitary Sewer is allowed with a Cosmetic Cleaning permit. [/FONT][/FONT] (Needs to to, confusing, right below this you say some cities require it and some do not)
[FONT=Arial,Arial][FONT=Arial,Arial]

- Some cities require a permit others do not. Contact your Public Works department for your city's requirements. The Public Works department may need to direct you to another department.

 Discharge must be in compliance with local regulations and limits (Solids less than 250 mg/L, Petroleums less than 250 mg/L) (Needs to go confusing and doesn't mean a thing at the local level), and may require pre-treatment, sampling, and possibly other measures.


- This will depend on the municipality.

- The city of Fort Worth has never been able to detect wash water from Cosmetic Cleaning in their POTW (Publicly Owned Treatment Works).

 Ensure pH of the wash water is between 5.0 and 12.0 (use pH test strips) and below 150˚.


- These limits are typically above normal Cosmetic Cleaning wash water.

 Filter using the best available method that removes the largest amount of contaminants.


- Sand Trap, Grit Trap, Grease Trap or Clarifier.

- If these options are not available then discharge to a mop sink, utility sink, kitchen sink, toilet, inside floor drain, or Sanitary Sewer clean-out stub.

- Never remove the Sanitary Sewer or Storm Drain manhole cover as these are City Property and require authorization to open. 5

[/FONT][/FONT]
Discharge to Landscape Areas - 2nd Choice


[FONT=Trebuchet MS,Trebuchet MS][FONT=Trebuchet MS,Trebuchet MS]For discharges to landscape areas you must do the following: [/FONT][/FONT]
[FONT=Trebuchet MS,Trebuchet MS][FONT=Trebuchet MS,Trebuchet MS]

[/FONT][/FONT][FONT=Arial,Arial][FONT=Arial,Arial]- Obtain the property owner’s permission.

- Ensure discharge volume is small enough that it soaks into the ground without running off property. Limit your discharge to 1,000 gallons/acre per month. (should add, "in any one area")

 On property wash water discharge can only occur at the property where the wash water is generated.

 Do not discharge repeatedly to the same landscape area because doing so may contaminate soil and groundwater, damage plants and cause other nuisance conditions.

Off property discharge can cause serious harm to groundwater. (once again here we are doing the EPA's job for them. This sentence needs to go)


-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. (This is not a big issue with the EPA at the moment plus it opens the door for guys like Jeff LeCours to be put out of business or forced to by tens of thousands more in equipment to do a job that is already environmentally friendly. Do you dislike Jeff Lecours that much?)

 Ensure pH of the wash water is between 6.0 and 9.0 by using pH test strips.


[/FONT][/FONT]Recycled Wash Water - 3rd Choice


[FONT=Arial,Arial][FONT=Arial,Arial]If the wash equipment being used recycles the water for reuse, the following may apply. [/FONT][/FONT]
[FONT=Arial,Arial][FONT=Arial,Arial]

- All discharge locations are to be reported to the Sanitary Sewer Department in advance of discharging wash water.

- Recycled wash water typically must be tested annually and the results reported to the Sanitary Sewer Department as required.

 Recycling wash water has the effect of concentrating the contaminants and pollutants. The POTW (Publicly Owned Treatment Works) do not typically accept concentrated waste water. 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. (Add this option it not usually practicable and is detrimental to the market and will result in costs that deter frequent health and safety cleaning, thus is not recommended except in cases where contamination of waters of the US is imminent and there are no other feasible options.)


[/FONT][/FONT]Discharge to Storm Drains - not recommended (Get rid of this garbage,)


[FONT=Arial,Arial][FONT=Arial,Arial]Never discharge detergents, chemicals, or hot water to Storm Drains. [/FONT][/FONT] (Add, hot water that will reach ambient temperature prior to reaching any receiving waters is acceptable)
[FONT=Arial,Arial][FONT=Arial,Arial]
 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. (Get rid of this entirely)

 Water that is greater than 110°F is considered hot water and considered the same as using soap. (Take this verbiage, burn it, curse it, stomp on it, and hope no one ever repeats it.)


- Hot water is an emulsifier and similar to using a detergent. (Ditto!)

 Discharges must be free of foam and oil sheen.


- An oil sock will remove foam and oil sheen.
[/FONT][/FONT]
Click to expand...


I've outlined deletions in Red above and my comments in blue. This took about 10 minutes and is, of course, not worded as it would need to be for legal purposes but is just written as a simple example of how to take this document that makes us all have to reclaim and try to turn it into a document that allows us to work using common sense.
 
Robert do you believe transportation companies primary reasons for cleaning fleets are for cosmetics?

The rear area of a restaurant is Ckeaning because they care how it looks as the primary reason.

Do you believe a fueling station cares more about the looks or the hazards grease and fuel accumulating makes when neglect happens?

I would be more well off if I could sell or anyone would really care about cosmetics.

There are some who do, unfortunately that's not the main reasons my clients use me.


Text me anytime for question 480-522-5227
 
I've got a better idea than fixing Robert's BMP's.

Let's scrap them altogether for some BMP's written by regulators for our industry since we can't seem to get anyone to be an advocate for us. These BMP's for Las Vegas are less restrictive and show the contract cleaner in a better light than the PWNA's own BMP's. Please read them everybody, just skip to the area that covers the kind of washing you do. It will only take a few minutes.

http://www.lvstormwater.com/pdfs/bmp_brochure.pdf


At least these regulator inspired bmp's give us a little credit and show that we are doing something for the environment. That's more than our own org's Bmp's did.

vegasbmp1_zps104b8f88.jpg


It gives us the option to use our own common sense in runoff to landscape.

vegasbmp2_zpse657d8e2.jpg


And it slams the "nothing down the dr@in but rain myth with a list of activities that are just fine to go down the drain with NO MENTION OF WATER TEMPERATURE.

vegasbmp5_zps8bb1cdd8.jpg


The Las Vegas BMP's are not perfect, but they are more contractor friendly and more complementary to the contractor than anything the PWNA or Robert has ever put out.

Maybe we should hire some regulators to represent us to the regulators.
 
Hey Tony-- if people are telling you no one cares-- just from a couple days when Guy Blackmon posted somewhere in here that this thread is nearing 8000 views, it's now approaching 10,000. Robert called me the other day about this thread and my advice is to keep posting if he can take it.

I'm actually calling him as soon as I post this-- how's this for a turn of events. You want to play with fire.. And you obviously are passionate enough(your wife is going to shoot me what I'm about to say & if she does tell her to get in line with Kathy for the things I get involved in..lol)

Maybe you should be the lead advocate. I don't have the funds or the brains for stuff like this.. Maybe you should put the $$$ where your mouth is and take the reigns by the horns... If that doesn't sound daunting enough.. Then maybe go all in.
 
Robert Hinderliter said:
Ron:

Is Jim G using your pictures for Garage Cleaning?

http://s111.beta.photobucket.com/user/RonMusgraves1/media/Photo-0018.jpg.html?sort=6&o=347
Click to expand...

Really Robert? We've reached the stage in this conversation where your attention turns away from runoff, BMP's and the EPA and goes to Ron's personal photobook page?

Is that why I got a call from a background investigation agency this morning? I can post the incoming call number screenshot on my phone just in case anyone thinks I made that up. I don't know if it has anything to do with you, but I've never gotten a call like that before today, ever.

What are you looking for in Ron's Photobucket?

I couldn't resist. I clicked on the picture and looked at it too after you posted it. What I saw was the same old Ron I've known since 2008. Plenty of pictures of completed jobs and demos, lots of pictures of his kids, his family, a few screenshots of old goofy threads and the one thing that sticks out more than anything......lots and lots of shots of contractors Ron has traveled all over the country to interact with over the past years.

Well, thanks for the sideline Robert, Now I'll get back to work.
 
This thread right now is getting viewed at least once a minuteTony I just got off the phone with Robert. There's not to many people who can hang on the net with Robert when it comes to being technical. Your running with him. You got center stage.. So what's your plan of action?
 
Clean County PW said:
This thread right now is getting viewed at least once a minuteTony I just got off the phone with Robert. There's not to many people who can hang on the net with Robert when it comes to being technical. Your running with him. You got center stage.. So what's your plan of action?
Click to expand...

My first action, if I had the power would be to limit both Robert and Jim from contacting anyone outside their own service area without a consensus on the content of the contact. And maybe even requiring all phone contact with regulators be recorded or on a conference call with two contractors till we can get some truth out instead of one or two contractors twisting words and working towards an agenda that is detrimental to the industry.

Then maybe we can work towards educating our contractors while making our industry look like the cleaners we are.
Finally I would like work towards a level of trust with the regulators so that we can work in peace.

But that is my dream situation.

Sent from my DROID RAZR using Tapatalk 2
 
Tony Shelton said:
Guess what Nigel, it doesn't matter what they want. Is this structure on private property? If so, they have no jurisdiction on the property as long as your runoff does not pose an imminent threat.

In order for them to have jurisdiction at all your runoff would have to go off the property and be tested to be an imminent threat to the "waters of the US".

Once this structure is in place it is up to the property owner to maintain it. You can help them.

It is your job to help your customer out by cleaning the property and filtering your runoff to the best of your ability to reduce maintenance on this structure. You do that by pre-cleaning the area for trash and debris, then filtering the runoff before it enters the structure.

This type of structure (on a much smaller scale) is what I proposed to our stormwater authority to be installed at any older non-compliant properties. They were elated at the idea and said it would be a perfect solution.

Call them back and ask them to show you where they have jurisdiction to tell you what you can and can't do on private property as long as the runoff that leaves the property poses no imminent threat.

Everybody will tell you what they "want", but what they are legally required to "have" may be two different things.

In Nevada I don't have to have license plates on my lift because it is a dedicated piece of equipment less then 6 ft wide. I called four places, Police, Highway Patrol, DMV, and the county and all four of them told me I had to have plates. Shelly owned a DMV service and she told me they were WRONG and showed me the statute. I've been pulling it for 5 years now with no plates and am perfectly legal.
Click to expand...

Robert Hinderliter said:
This type of structure is under the jurisdictrion of the EPA, and they can come on property to inspect it. It is part of their SWPPP which is under the jurisdiction of the EPA.
Click to expand...

I was informed by local AHJ the installation is private, but the property was mandated by the state to have installed , and maintained. In most cases these installations have an agreement, the AHJ has authority to enter property to inspect, order corrective action etc.
 

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810f250 said:
I was informed by local AHJ the installation is private, but the property was mandated by the state to have installed , and maintained. In most cases these installations have an agreement, the AHJ has authority to enter property to inspect, order corrective action etc.
Click to expand...

Nigel: I was informed by the Federal EPA they the have a right to enter property and inspect these as part of the SWPPP.
 
You know Tony you could just copy and paste them and say they are yours loan them to us and charge 25 bucks per CD
Tony Shelton said:
I've got a better idea than fixing Robert's BMP's.

Let's scrap them altogether for some BMP's written by regulators for our industry since we can't seem to get anyone to be an advocate for us. These BMP's for Las Vegas are less restrictive and show the contract cleaner in a better light than the PWNA's own BMP's. Please read them everybody, just skip to the area that covers the kind of washing you do. It will only take a few minutes.

http://www.lvstormwater.com/pdfs/bmp_brochure.pdf


At least these regulator inspired bmp's give us a little credit and show that we are doing something for the environment. That's more than our own org's Bmp's did.

vegasbmp1_zps104b8f88.jpg


It gives us the option to use our own common sense in runoff to landscape.

vegasbmp2_zpse657d8e2.jpg


And it slams the "nothing down the dr@in but rain myth with a list of activities that are just fine to go down the drain with NO MENTION OF WATER TEMPERATURE.

vegasbmp5_zps8bb1cdd8.jpg


The Las Vegas BMP's are not perfect, but they are more contractor friendly and more complementary to the contractor than anything the PWNA or Robert has ever put out.

Maybe we should hire some regulators to represent us to the regulators.
Click to expand...
 
Tony Shelton said:
I've got a better idea than fixing Robert's BMP's.

Let's scrap them altogether for some BMP's written by regulators for our industry since we can't seem to get anyone to be an advocate for us. These BMP's for Las Vegas are less restrictive and show the contract cleaner in a better light than the PWNA's own BMP's. Please read them everybody, just skip to the area that covers the kind of washing you do. It will only take a few minutes.

http://www.lvstormwater.com/pdfs/bmp_brochure.pdf


At least these regulator inspired bmp's give us a little credit and show that we are doing something for the environment. That's more than our own org's Bmp's did.

vegasbmp1_zps104b8f88.jpg


It gives us the option to use our own common sense in runoff to landscape.

vegasbmp2_zpse657d8e2.jpg


And it slams the "nothing down the dr@in but rain myth with a list of activities that are just fine to go down the drain with NO MENTION OF WATER TEMPERATURE.

vegasbmp5_zps8bb1cdd8.jpg


The Las Vegas BMP's are not perfect, but they are more contractor friendly and more complementary to the contractor than anything the PWNA or Robert has ever put out.

Maybe we should hire some regulators to represent us to the regulators.
Click to expand...

Tony: If you were familar with the EPA's Model Ordinance, than you would see that the above are Modeled after that ordinance. Overall, they are more restrictive. You making up your mind before reading.
 
Robert Hinderliter said:
Tony: If you were familar with the EPA's Model Ordinance, than you would see that the above are Modeled after that ordinance. Overall, they are more restrictive. You making up your mind before reading.
Click to expand...

No mention of hot water anywhere.

Sent from my DROID RAZR using Tapatalk 2
 
http://www.propowerwash.com/board/upload/showthread.php?15605-COSMETIC-CLEANING-BMPs

Robert I'm not meaning to beat you up, but if your intentions are what you say. WHY is there threads like this all throughout the internet?

Is it enough PWNA and UAMCC members pay dues to belong to something thats suppose to represent more.

Mean while over all the years you have charged for safety and enviro education.

I hope that in the futures we can build and industry full of awareness that can truly take the business people to a higher place. This way has not worked for anyone but a few. Which has not created a stronger industry for anyone, it breeds more Hacks.
 
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