EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Guy Blackmon said:
Chris, isn't this why the "Pumper Truck Companies" were all up in the Houston meetings?
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I am guessing so, several of the company reps I talked to mentioned that companies selling reclaim equipment are trying to sell the city on the idea of these expensive machines and hauling away the wash water and most of the contractors there in Houston could not afford them so they are there to sell the contractors the vacuum and hauling services. One of the vacuum truck company reps told me that a reclaim machine company called them and gave them their speech about reclaim and recovery and they just laughed at them because it sounded so ridiculous and it was obvious that they had not seen a vacuum truck before or knows what it can do.

What was interesting is that since so many contractors could not afford the expensive recovery systems that were being recommended to the city and to the contractors, the vacuum truck companies were more than eager to help out starting at about $65.00 per hour per truck and 1 person but a couple of the companies told me that they don't send any trucks out with only 1 person for safety concerns, the extra guy will cost another $35 per hour, clock starts when they leave their yard until they get back to their yard.

The city of Houston was not telling the contractors about the legal D.O.T. issues related with hauling hazardous waste as it is obvious that the city did not know or was not telling anyone, either way, that is wrong to tell someone to haul hazardous waste without informing them that they have to be a licensed waste hauler to do so in order to not get seriously fined.

After attending that meeting there in Houston, I really felt bad for all the contractors there in the Houston area because of all this nonsense and hoops to jump through just to do a job and they did not know about the structures and proper building codes to eliminate most of this nonsense. Glad Ron Musgraves went there numerous times to educate the city of Houston and their officials on what the CWA really says, means and the correct interpretation of what commercial cleaning is done properly.

The officials really did not know what the CWA means (they probably never read it), they are making up ordinances and regulations as they went along and as they see fit in order to become a money maker for the city by fining the contractors (mostly fining them illegally when it is looked at) but it cost a lot of money to hire the right kind of attorney to help you in these matters and for some contractors it cost less to just pay the fines. A couple of contractors I talked to before the meeting started mentioned that they were thinking about getting out of the business due to the city harassing them so much.
 
Ron Musgraves said:
If those are actually Storm drains you should report these to the authorities, I'm not telling you to rat out contractors but careless contractor & developers who in malice did not comply because of MOney.

Likely your incorrect about them being storm drains.
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No I never said the the drains in some of the garages we do where the water doesn't even go to the drain so it puddles up in between are storm water drains. The top exposed floors in some parking garages we have done are hooked to the storm drains because there exposed to rain. These drains as far as I know are not hooked into any type of water/oil separators because on a torrential rain downfall those water/oil separators could flood out and that would be a horror show.
So no I'm not talking about these slightly off pitched floor drains are storm water drains..
As far as the designing of the garages and these pitches being off FYI I had this exact conversation with at least 5 facility managers this year. Guys who do garages will know exactly what I'm talking about.

When we clean out the sludge the majority of it comes in the area of the drains we have a berm and filter on and around them. That's understandable but the frustrating part is the puddle/ floods that form between the drains. So yes it's shoddy engineering work or could it be the garages settled so much there floor pitches in area's went off a degree or to? I hope that's not it.
 
Clean County PW said:
Also Ron are you suggesting that under no circumstance can we dislodge our cleaning water onto the landscape area's?
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I'm saying that if garages are built compliant and you collect and dispose of poison on the lawn you should be prosecuted.


Text me anytime for question 480-522-5227
 
Christopher said:
The officials really did not know what the CWA means (they probably never read it), they are making up ordinances and regulations as they went along and as they see fit in order to become a money maker for the city by fining the contractors (mostly fining them illegally when it is looked at) .
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Chris you pretty knowledgable in these areas as well. You have to admit it is pretty interesting but do you really believe a town operates like that where they just make up ordinances and regulations for the heck of it without no consideration of doing it illegally? Now the whole town can be held accountable since this stuff was just made up? Do you really believe that Chris?
Tell me what officials did that so I can research it out and pass it over to some hungry lawyers here so they can own that town and maybe I can get a piece of it myself. How much for your cut..lol
 
Ron Musgraves said:
I'm saying that if garages are built compliant and you collect and dispose of poison on the lawn you should be prosecuted.


Text me anytime for question 480-522-5227
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Bingo.. We finally agree on something!!! Hip hip Horaaaay!!!Happy Birthday(no thats frosty the snowman) Happy New Year!! Never ever take a garage that's on a typical "Not enough cleaning cycle" routine and discharge it on the landscape area ever or you find yourself pumping gas for a living.

How about gas Stations and commercial store fronts? Can you discharge on the landscape area's?
 
Message to meMan I love these threads...Russ says stay civil.. Do what Russ says... Good for your own business growth... Russ is spot on.. Easy to see that... Do not get angry with Ronny boy even when he blows up my phone.. Smile & be nice..

Do not give anyone any reason to officially ban me for real(well longer then 4 days before that was overturned).. Follow message to self... Just having fun.
 
Clean County PW said:

Chris you pretty knowledgable in these areas as well. You have to admit it is pretty interesting but do you really believe a town operates like that where they just make up ordinances and regulations for the heck of it without no consideration of doing it illegally? Now the whole town can be held accountable since this stuff was just made up? Do you really believe that Chris?
Tell me what officials did that so I can research it out and pass it over to some hungry lawyers here so they can own that town and maybe I can get a piece of it myself. How much for your cut..lol
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I think that Robert H. video taped that event, go and watch it.

That was almost 2 years ago and I don't remember names of people that well, especially those that are clueless and are dumbazzes.

Yes, I really belive that those people are clueless for the hauling waste water regulations as a lot of people out there are who don't have CDL. That is why they were telling contractors to just haul away the wash water. They wanted to inspect your tank and trailer first but if you have a CDL like some of us do, it is not up to them when on public roads and highways if you are compliant according to D.O.T. regulations. Watch the video, you will see where they say that they want the contractors or have the contractors haul away the wash water. If you are serious and pursue this, give me a percentage that you think is fair, no problem with me on that one.

If the city officials had any clue, they would tell the contractors that only licensed waste haulers can legally haul hazardous waste or that contractors have to get the proper training, get the proper commercial vehicles, CDL with hazmat endorsement, etc..... but they did not as they had no clue about this whatsoever. Again, send me a percentage that is fair. As a responsible city or group of officials they should have told the contractors what I just typed so they would have covered their asses but they did not. Watch the video, I believe it was mentioned at least a couple times.

That is why so many vacuum and pump truck companies were there at the meeting so they can help out contractors so they would not get the huge fines by the State Police, D.O.T. officers and State Troopers, these guys know just about every regulation in the book like no cop I have ever seen in my life. I guess they are the top of the top to know so much. When you think about it, by the city not telling contractors about the D.O.T. regulations, it is a great selling point and decent scare tactics for the vacuum truck and pumper truck companies selling their services to the pressure washing contractors, who knows, maybe the city did not tell the pressure washing contractors on purpose to help out the vacuum truck and pumper truck companies? Scandal in a big city, no, it could not be so when big cities are just so honest.

Anyway, go and watch the videos and see for yourself how they had a hard time not answering my questions along with questions of other contractors in the room because there is so much they really did not know. This may seem hard to believe but watch it for yourself and listen closely and see how even when they got help answering, the answers changed several times.............(drum roll here).............................because they really don't know and contractors were paying fines for this nonsense.

Now, thanks to Ron Musgraves help going there numerous times and educating the city and officials, they are heading down the right road finally after years of being mis-informed by vendors and others that had their own purposes in mind and not reading the CWA for themselves and understanding it along with understanding properly built commercial facilities are built to handle commercial power washing without the wash water ending up in the MS4. Hope this helps and makes it clear.

Let me know when my check is in the mail.
 
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Clean County PW said:
Bingo.. We finally agree on something!!! Hip hip Horaaaay!!!Happy Birthday(no thats frosty the snowman) Happy New Year!! Never ever take a garage that's on a typical "Not enough cleaning cycle" routine and discharge it on the landscape area ever or you find yourself pumping gas for a living.

How about gas Stations and commercial store fronts? Can you discharge on the landscape area's?
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Truthfully John you should just take Jerry Program, everything is Based on Site assessment.

The PWNA & Mostly Robert believe in this one BMP fits all, we know this because he combines Data from different arts and confuses himself with people who are actaully waste creators.

We for the most part in the Sidewalk cleaning business do not have a product like in a factory that has a waste by product. Comparing these two things together and posting about them on a powerwash forum has nothing to do with the other. The only thing that brings the association together is Robert who is working with the PWNA.

He really needs to stop doing this, its potentially damaging to the industry.
 
Newlook said:
Nigel....how ya doing man?

I use the vacumn in any situation where there is more than likely chance that the waste water will either:

1. Go off site
2. Enter a storm drain

As far as the ownership of the water...never came up nor was discussed.

Waster water recommendation for discharge has come from 2 difference counties and they all said the same:

1. Landscape
2. Sewer Drain (see video) - I think you have seen this vid before Nigel. We are discharging in a sanitary sewer onsite.
3. Janitors closest.

On the landscape part there is a ratio of how much waste water per acre is allowed in the landscaped area. The recommendation is 1,000 gallons per month per acre, and not puddle up the water so that when it rains it will wash off the property. Make sure the waste water does not reach the ground water supply.

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What if your by-passing systems in place?
 
810f250 said:
Chris C, I understand your point, I dont want to transport any water whats so ever if possible clean or soiled.

I have to say I do not fully understand all of the issues that Huston contractors experienced.

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Appreciated Russ S for the clarification. Congrats on increasing business, what changes are you attempting to make in your area?


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Guy B, I would venture to say if it is a closed to any body of water of the US, and if it is utilized within its designed parameters then there is no infringement.


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Carlos G,

In what situation do you have to use your vacuum system?

What is your local AHJ opinion on the ownership of wash water that is used and picked up by wash operation ?

Where does your local AHJ recommend that you dispose of the picked up wash water?

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Ron M, in a garage pressure wash cleaning that is performed more frequent will most likely produce less sediment during cleanup, nevertheless how is the wash water and sediment managed?

I will look up the phone numbers for the fuel station in the video and get them to you.
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Bumping these questions it may have gotten over looked in the activity of the thread.



Newlook said:
Nigel....how ya doing man?

I use the vacumn in any situation where there is more than likely chance that the waste water will either:

1. Go off site
2. Enter a storm drain

As far as the ownership of the water...never came up nor was discussed.

Waster water recommendation for discharge has come from 2 difference counties and they all said the same:

1. Landscape
2. Sewer Drain (see video) - I think you have seen this vid before Nigel. We are discharging in a sanitary sewer onsite.
3. Janitors closest.

On the landscape part there is a ratio of how much waste water per acre is allowed in the landscaped area. The recommendation is 1,000 gallons per month per acre, and not puddle up the water so that when it rains it will wash off the property. Make sure the waste water does not reach the ground water supply.

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I am good Carlos, Happy new year!

Thanks for your response, I have seen the video, did you ever try the suggestion of screening the pump, I remember you mentioned pumpout clogging issue.

Does your POTW's require a permit for mobile wash water discharge ?

On the use of landscape discharge, which department of your local authority advised its use and parameters (for may area it was the counties Storm Water Management Division)



Ron Musgraves said:
I'm saying that if garages are built compliant and you collect and dispose of poison on the lawn you should be prosecuted.


Text me anytime for question 480-522-5227
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Ron, what is your opinion of commercial properties that are "not built compliant" ?

What does "not built compliant" mean?

What is your opinion of a scenario where a mobile wash contractor picks up their generated wash water form one area of "compliant property", to avoid it reaching a storm drain (because of the volume of wash water produce and location of storm), and having to transfer the wash water to an area on property where it will comply with the CWA?



Ron Musgraves said:
What if your by-passing systems in place?
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What if there are instances where there are no systems in place?
 
I have talked to many guys around the country and most potw's like here will accept the wash water after you take the sediment and oil/grease out of it and filter it to about 20 microns, no big deal. Most can build an inexpensive system that will do this for under $1000 or a lot less depending on the situation.

This is not needed most of the time as Ron has talked about this kind of thing for many years now under many different topics in many different threads, they are all there for anyone to see, read and learn about so you don't have to buy expensive equipment for most types of cleaning (not talking about garage cleaning here, just the most other types that most of us do).

When you go and read these older posts, you will understand what Ron has been teaching through these threads and more and more contractors see how you can do many, many different types of commercial cleaning without needing specialized recovery/reclaim equipment as it is really not needed once you understand what Ron has been talking about for many years now.
 
Ron Musgraves said:
Simple, use less water, wash more often the waste can be controlled and properly contained. Proper disposal is easy once you learn to control and contain.


More frequent washes are more responsible not to allow a sludge situation to ever happen. My friend Jim Zadrill taught me back in 2002 along with kendra while attending a round table. We got to watch his crews clean a Mall on ocean front. The closer to the water he got the less water he used.
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This is a true statement. Two years ago I visited with the city of Chattanooga storm drain people and their concern was not the amount of water going in the storm drains but the amount of sludge. In fact they told me that they test the drains for sludge and oils. They were more concerned about resturants than they were about gas stations. Once when they were checking as we were washing a Chilis they saw we had oil socks at the drain and gave us a thumps up and kept on driving.
 
810f250 said:
My intention is not to make anyone that Ron, and I do appreciate when post take on that connotation.

I am open to calling and hearing the AHJ's position for that property.
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Ron Musgraves said:
Nigel Allow me to call and use the proper terms, you will understand this better. you will also understand they are un-educated on there own involvement and jurisdiction.
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As promised here is the phone directory for Montgomery County Maryland Department of Environmental Protection, ..........I am truly interested in observing and learning what to say, ask, what not to say, to an AHJ about providing pressure cleaning service of the fueling pad for this location in the Maryland Gas Station Video, and their position on the use of that installation for mobile wash water containment.
 
Christopher said:
I have talked to many guys around the country and most potw's like here will accept the wash water after you take the sediment and oil/grease out of it and filter it to about 20 microns, no big deal. Most can build an inexpensive system that will do this for under $1000 or a lot less depending on the situation.

This is not needed most of the time as Ron has talked about this kind of thing for many years now under many different topics in many different threads, they are all there for anyone to see, read and learn about so you don't have to buy expensive equipment for most types of cleaning (not talking about garage cleaning here, just the most other types that most of us do).

When you go and read these older posts, you will understand what Ron has been teaching through these threads and more and more contractors see how you can do many, many different types of commercial cleaning without needing specialized recovery/reclaim equipment as it is really not needed once you understand what Ron has been talking about for many years now.
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20 microns is very small Chris, my local POTW is a little more relaxed.

pdmcali said:
This is a true statement. Two years ago I visited with the city of Chattanooga storm drain people and their concern was not the amount of water going in the storm drains but the amount of sludge. In fact they told me that they test the drains for sludge and oils. They were more concerned about resturants than they were about gas stations. Once when they were checking as we were washing a Chilis they saw we had oil socks at the drain and gave us a thumps up and kept on driving.
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If they can standardize the use of oil socks across all AHJ's for each local this would be great.
 
Nigel, a directory?????


Please you have been working with someone , names please. I have limited time, I can call any GOV place and get the answer i want to hear simply by finding the dumbest person. Direct me to the people your working with, the ones you refer will not allow. PLEASE
810f250 said:
As promised here is the phone directory for Montgomery County Maryland Department of Environmental Protection, ..........I am truly interested in observing and learning what to say, ask, what not to say, to an AHJ about providing pressure cleaning service of the fueling pad for this location in the Maryland Gas Station Video, and their position on the use of that installation for mobile wash water containment.
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A couple of points of clarification from what I have learned:

I have been involved in tested a lot of Mobile Power Washing Waste Water. For recycling under 16 hours then discharging the waste water and replacing with fresh water, effluent never tested Hazardous by a TCLIP Test.

For waste water from normal power washing that was remediated with a screen filter and oil absorbent boom that removed the oil sheen, also never tested Hazardous.

About 1995 both Texas and California said that hauling waste water that was not hazardous did not violate state codes, however, some municipalities do regulate this transportation. In other words for the most part you do not have to have a Hazardous Waste Haulers Permit to haul your waste water that is not hazardous.

Retention Ponds: I investigate with several manufactures and designers of these at StormCon to get an overview of what they were designed to do.

Depending on the Municipality they are designed to hold a rain event from 100 years to 90 days depending upon the Municipality. The soil that is beneath the retention pond determines the design. It basically depends on how fast that the water will seep into the soil below. If they get more storm water than they are designed to hold then the water flows to the MS4. If you get a very rainy season then the seepage may reach the ground water. An example is all of the flooding the occurred last year.

Also most are designed to catch trash at the inlet, but not FOGs. A pocket survey of the Manufactures present said that very few were designed for FOGs. Therefore, there is a slight risk in discharging to the Retention Ponds. You will always need to filter for sludge and FOGs before discharging.
 
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