Lets Talk Only Serious Please CWA education 303- Houston problems Official Q & A

http://www.epa.gov/earth1r6/6en/w/pw.htm

Lets talk about this local authority getting way over there heads with the interpetation of the federal guidelines.

Yes we realize they can be stricter, they can also be at the same standards of the laws the feds created.

Why did they go over board? Or is the enforcement mis-interpetation of the law the actaul problem.


Seriously this thread will be only about serious issues not politics.

We as and industry in order to fight this just need to understand it.

I will be traveling to Houston in the real near future. I will put together free handouts to educate the contractors so we can effectively argue this now and in the future.

I'm truly sorry that I have not shared my knowledge that keeps me operating under guidelines as strict in my own city.

Its time for the industry to seek the education so they can protect themselves agaist people who are trying to hurt there family's and pocket book.

This thread is about understanding the law and the jusrisdiction of the law.

The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States. If your discharge does not reach waters of the United States, then there are no requirements under the CWA. Examples of compliance without a discharge are vacuuming up the process wastewater or berming the process water and allowing it to evaporate. An additional method of compliance is to discharge the water to an NPDES permitted sanitary sewer system (the municipality may have additional pretreatment requirements before accepting your discharge). The most common form of non-compliance is to discharge the process water into a storm sewer system or into a city street that drains to a storm water inlet. Most storm drainage systems in Region 6 discharge directly to waters of the United States without treatment, which means anything that discharges into a storm drain is the same as putting it directly into the waterbody receiving the storm drain discharge.

Click to expand...

Understand how Houston gets around this is they made a city ordinace that says any water reguardless how it got on property is texas State waters. You cannot remove this with out there permission.

This is a huge problem, last I checked you need the army corp of engineers permission to move state waters. This is one flaw right out of the gate, a mistake houston made. They do not have the authority to grant permission.


CHECK

This is why when a person gets a citation and shows up with lawyer its dismissed.

"last I checked you need the army corp of engineers permission to move state waters."

Very true Ron, seems Houston is making the rules up as they go. Why City Officials did not want to "Work With Contractors" is beyond me. From what I understand their stance is "This Is The Way It Is Like It Or Not, We Don't Need to Explain Anything" I do not understand this mentality. In my experience working with N.C. State and Local Water Authorities, they want and search out input from people that new rules and regs may affect. Public forums are law when new rules and regs. are going to be discussed. Many high profile Political figures attend these meetings.

Great info Ron, Thanks.

Most of what Houston is doing does not make sense.

It is very strange how they want so badly for you to haul away the wash water to the specified place. First you have to pay the application fee of $119.00 then pay either monthly (I forgot how much) or yearly of $660.00 then you have to have your rig approved to haul the waste.

You have 4 days from the time you finish the job to turn in the manifest to the city (paying $3.50 for each invoice) and who knows how much you have to pay to dispose of the wash water?

The city wants you to haul hazardous waste but are not telling you the Federal D.O.T. regulations for hauling hazardous waste (you really don't want to be pulled over hauling hazardous waste by a state trooper or D.O.T. officer as you will look at serious fines and/or jail time and equipment inpounded).

There are so many things wrong with what they are doing, it will be hard to know where to start fixing things once they realize how wrong they are.