BMP's for WI and MN

Neal Forrest

New member
Hello everybody. My name is Neal and I am a new member to this BB, the PWNA, and the pressure washing industry. What a time to enter this arena, but what a time to tap into the the vast resources of the members here and abroad so I can be on the right track for a successful business.
Houston and the PWNA proposed BMP's got me to thinking about what is going on here in the Twin Cities metro area. It took a while, but I finally got a sort-of answer today. It included statute quoting, suggestions (but these were useless as you will see) and - drum role please - an actual BMP written by those folks that actually, sort-of, enforce them. Since I have very little experience, I will just post the responses from the MPCA - MN Pollution Control Agency

I have copied and pasted and email from Tom Jablonski of the MPCA to another contractor in the area who contacted him last fall. It says:

Powerwashing in MN

The ultimate goal managing your power-washing operations should be to prevent the discharge of pollutants into the waters of the State. Pasted below is the excerpt from the Minnesota Administrative Rule (https://www.revisor.leg.state.mn.us/rules/?id=7001.1030) that prohibits the discharge of pollutants to the waters of the state without a permit below. As long as you aren't discharging pollutants, then you would not need a permit.

Possible ways to prevent the discharge would be to first of all minimize the amount of water used in your cleaning operations. For cleaning pavement surfaces, use of a broom or other dry removal practices should be used first. Spot cleanup of spills should also be done first. Work with customers to make sure they implement management practices that keep their pavement clean in the first place. Then if you still need to use powerwashing, look into collecting the washwater and running it through a cleaning system so the water could be reused. If you can do this then look into collecting it and then bringing it to a wastewater treatment system that would accept the water. If all of those options are evaluated and implemented and you still need to discharge water then the attached document provides some examples of management practices that should be implemented.


Then he goes on to include the statute he eluded to in his email. It is listed as follows:

7001.1030 PERMIT REQUIREMENT AND EXEMPTIONS.

Subpart 1. Permit required. Except as provided in subpart 2, no person may

discharge a pollutant from a point source into the waters of the state without obtaining a

National Pollutant Discharge Elimination System permit from the agency.

Subp. 2. Exemptions. The following persons are not required to obtain a National

Pollutant Discharge Elimination System permit:

A. persons who discharge sewage or effluent from a vessel;

B. persons discharging dredge or fill materials regulated by the federal

government under section 404 of the Clean Water Act, United States Code, title 33,

section 1344;

C. persons discharging pollutants to a publicly owned treatment works;

D. persons discharging pollutants who are in compliance with the instructions

of an on-scene coordinator in accordance with Code of Federal Regulations, title 40,

part 1510;

E. persons introducing pollutants from nonpoint source agricultural and

silvicultural sources into privately owned treatment works;

F. persons causing return flows from irrigated agriculture;

G. persons discharging pollutants into privately owned treatment works;

H. persons injecting water, gas, or other material into a well to facilitate the

production of oil or gas; and

I. persons disposing of water in a well if this water is associated with oil and

gas production.

Statutory Authority: MS s 115.03; 116.07

History: 8 SR 2277; 13 SR 2453; 19 SR 1901

Posted: July 13, 2009

Alright, that is all I have. How's that for a first post! Thank you to all who have kept me learning and entertained for the last two weeks while I just lurked in the shadows. :grin-devilish: More to follow!
 

Attachments

  • Outside Washing BMPs.doc
    34 KB · Views: 9
Thanks for the well wishes everyone. Paul, that was a great class and I learned a ton. Who would have thought i would meet such titians in the pressure washing industry in my first class? And that they would be gracious with their time and knowledge!

This post has gotten me an invite to a meeting of the minds so to speak. I believe that storm water and sanitary sewer will be represented. All we need now is a handful of pens and pocket protectors and we are set for one hell of a good time! I'll let you all know if we actually learn something.
 
Ron, I was not able to make it the day they met. But, Blaine K. and Mike H. were both there. Perhaps they would like to chime in with an update of how they were received and what was discussed?
 
Mike Hilborn from the PWNA went along with us when we met with Minnesotas branch of the EPA to discuss what they are expecting from our industry and see if anything has changed since we met with them the last time. It went well and they are a lot more educated on and willing to work with our industry compared to what is going on in Houston. We stressed to them that we ARE NOT POLLUTERS like the stigma that is unjustifiably attached to our industry but instead we clean up and dispose of pollution and went on to explain why. They said they had never looked at it from that direction but could certainly understand our points. Overall a very productive meeting and it opened new lines of communication. I appreciated Mikes help.
smiley.gif
Mike has written an article for "Cleaner Times" that discusses the meeting in greater detail. Make sure to read it there!
 
Thats great, we are making changes.

Maybe will see this Carry to the PWNA finally.



Mike Hilborn from the PWNA went along with us when we met with Minnesotas branch of the EPA to discuss what they are expecting from our industry and see if anything has changed since we met with them the last time. It went well and they are a lot more educated on and willing to work with our industry compared to what is going on in Houston. We stressed to them that we ARE NOT POLLUTERS like the stigma that is unjustifiably attached to our industry but instead we clean up and dispose of pollution and went on to explain why. They said they had never looked at it from that direction but could certainly understand our points. Overall a very productive meeting and it opened new lines of communication. I appreciated Mikes help.
smiley.gif
Mike has written an article for "Cleaner Times" that discusses the meeting in greater detail. Make sure to read it there!
 
How the BMP going in MN

Hello everybody. My name is Neal and I am a new member to this BB, the PWNA, and the pressure washing industry. What a time to enter this arena, but what a time to tap into the the vast resources of the members here and abroad so I can be on the right track for a successful business.
Houston and the PWNA proposed BMP's got me to thinking about what is going on here in the Twin Cities metro area. It took a while, but I finally got a sort-of answer today. It included statute quoting, suggestions (but these were useless as you will see) and - drum role please - an actual BMP written by those folks that actually, sort-of, enforce them. Since I have very little experience, I will just post the responses from the MPCA - MN Pollution Control Agency

I have copied and pasted and email from Tom Jablonski of the MPCA to another contractor in the area who contacted him last fall. It says:

Powerwashing in MN

The ultimate goal managing your power-washing operations should be to prevent the discharge of pollutants into the waters of the State. Pasted below is the excerpt from the Minnesota Administrative Rule (https://www.revisor.leg.state.mn.us/rules/?id=7001.1030) that prohibits the discharge of pollutants to the waters of the state without a permit below. As long as you aren't discharging pollutants, then you would not need a permit.

Possible ways to prevent the discharge would be to first of all minimize the amount of water used in your cleaning operations. For cleaning pavement surfaces, use of a broom or other dry removal practices should be used first. Spot cleanup of spills should also be done first. Work with customers to make sure they implement management practices that keep their pavement clean in the first place. Then if you still need to use powerwashing, look into collecting the washwater and running it through a cleaning system so the water could be reused. If you can do this then look into collecting it and then bringing it to a wastewater treatment system that would accept the water. If all of those options are evaluated and implemented and you still need to discharge water then the attached document provides some examples of management practices that should be implemented.


Then he goes on to include the statute he eluded to in his email. It is listed as follows:

7001.1030 PERMIT REQUIREMENT AND EXEMPTIONS.

Subpart 1. Permit required. Except as provided in subpart 2, no person may

discharge a pollutant from a point source into the waters of the state without obtaining a

National Pollutant Discharge Elimination System permit from the agency.

Subp. 2. Exemptions. The following persons are not required to obtain a National

Pollutant Discharge Elimination System permit:

A. persons who discharge sewage or effluent from a vessel;

B. persons discharging dredge or fill materials regulated by the federal

government under section 404 of the Clean Water Act, United States Code, title 33,

section 1344;

C. persons discharging pollutants to a publicly owned treatment works;

D. persons discharging pollutants who are in compliance with the instructions

of an on-scene coordinator in accordance with Code of Federal Regulations, title 40,

part 1510;

E. persons introducing pollutants from nonpoint source agricultural and

silvicultural sources into privately owned treatment works;

F. persons causing return flows from irrigated agriculture;

G. persons discharging pollutants into privately owned treatment works;

H. persons injecting water, gas, or other material into a well to facilitate the

production of oil or gas; and

I. persons disposing of water in a well if this water is associated with oil and

gas production.

Statutory Authority: MS s 115.03; 116.07

History: 8 SR 2277; 13 SR 2453; 19 SR 1901

Posted: July 13, 2009

Alright, that is all I have. How's that for a first post! Thank you to all who have kept me learning and entertained for the last two weeks while I just lurked in the shadows. :grin-devilish: More to follow!
 
I received a great email about a month ago. Totally forgot to post about it. Good, concise easy to follow stuff that makes a bunch of sense to me. I will post that email and BMP tomorrow, thanks for the reminder.
 
I received a great email about a month ago. Totally forgot to post about it. Good, concise easy to follow stuff that makes a bunch of sense to me. I will post that email and BMP tomorrow, thanks for the reminder.

Great stuff, you should tell pwi members about your background!!
 
But then I can't be the man behind the green curtain. Still trying to figure out how it will help everybody. When I do, I'll let you know.

Anyone in the industry with a type of back ground that can help!! You understand this better than most
 
Sorry this took so long to post, I finally am getting busy! The first part is the email I received, and the attachment is the official BMP that the MN Pollution Control advises all pressure washers to use. However, like Blaine said earlier, there is next to no enforcement at this time. No excuse to not be responsible, though! But, it certainly makes the waters a little less muddy for those of us in the Twin Cities. It took about a month, seven phones calls, and 5 emails to get this answer just in case anyone was wondering.
 

Attachments

  • Outside Washing BMPs_jmu (2)-1.pdf
    32.8 KB · Views: 12
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