EPA Enforcement in 2012 Protects Communities From Harmful Pollution

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Originally Posted by Tony Shelton
Regarding #1 and #2 you are underestimating Robert, John. He knows from experience that the AHJ's love cut and paste and they will take the Bmp's just like they are, just like some places did with the Ft Worth Bmp's.

The big problem (among others) here is Robert's BMP's make EVERYONE who cleans have to reclaim (because just about everyone uses hot water).

He knew this when he put them out. I informed him of it and he chose to steamroll all over everybody's objections.

Give him an award John, and let's all try something different. Robert was unwilling to work with us.
Clean County PW said:
Robert can you answer this and tell us if what Tony is saying is accurate and also what can we do about this-- Thanks
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That statement is based on ignorance; it does not say that. Watch the video on pwna.org .
 
I will be happy to answer questions about the interpretation of the EPA’s Cosmetic Cleaning Ordinance. Copy and paste the part you have questions about if they are not clear to you.

Also any part of the Video on pwna.org/environmental.
 
The day with an actual AHJ will happened and a few of us sitting in will happened. I'm curious to know who the guy was in Rons 3+min video because that Video was excellent. I definitely would like to see more of it because he looks like he had alot more to say that would be educational right here.

Also I would like to talk about the BMP's with one of these AHJ's to see if there on board with TONY and they consider them a RULE or a GUIDE.

Tony's point is that you have failed us. There's a couple of others who feel the same way in here. You have shopped a RULE and not a Guide that can be changed so you have failed them and contractors across the country.

That's what it looks like is going on here... So the only way to know for sure is to talk to an actual AHJ and see if they think first off it's wrong to give people many options in a BMP because you state clearly it can he changed to fit the needs of the area it could be used at.... also I would like an AHJ's opinion if he thinks the acronym BMP was ever manipulated in the outside world to scare people to promote it as a rule like Tony is doing here.

Also the impression I'm getting is that some don't want you Robert to go to any of these places with regulators because you understand there language and you can challenge them on there playing field whereas to say in there that a BMP is the rule of the land they would know right there that statement is incorrect.
 
We need to have an actual AHJ right here on PWI who would be willing to stay here for a few days to add comments where needed. The better step would be to meet 1-2-3 etc in the first faze to make sure where all on board OD whatnis correct. That would be a great stepping stone to begin to get to the next level. Knowledge from the correct sources is a beautiful thing.
That is why #1 I wish I did go to Houston and #2 when you have the knowledge or have people around you with the undisputed knowledge which turns into facts... That is force to be reckoned with.... And that is why this industry needs...
To be that force...
 
Robert can you or anyone here get me a copy or direct me to all the footage from the Houston video's? I want to study them to start building my own "Lack of knowledge" to see how I could start getting the right people together by some type acceptable form of communication.
 
Timothy said:
Yes, absolutely. But listen to what Ron says at the beginning of the video. This is a retention area. If it had trees, shrubs, and grasses planted on top of it it would be a bio-retention area.

Infiltration is secondary, first the structure must retain the water. And yes, a hole in the ground with crushed aggregate in it is a "structure" for purposes of SWM.

So when discussing this particular install, you would not call it an infiltration structure but would refer to it as a retention area.

-

To be correct, the illustration of the infiltration trench that you posted here earlier would typically have a grass buffer at less than 5% slope of at least twenty feet in length (or width) before the water from the impervious area entered the trench. This grassy area pre-filters the cig butts, sediment, etc. before the SW reaches the infiltration trench. Because the retention structure in Ron's video does not have a filter area, it should not be called an infiltration structure even though that is ultimately what it does.

Yes, we are splitting nits here but Nigel seeks a deeper understanding so I will do what I can to help him develop it. :smile:
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Thank you Tim, I do appreciate the input, and seek a better understanding.

I just received a return email from (Storm Water Management Structures with in the Department of Public Works of Howard County Maryland) with some of my questions answered about the installation pictured below, but some of the questions needed to be referenced to three other departments within the county, ahh the red tape.

I then called The Development Engineering Division (DED) in the Department of Planning and Zoning and the photo below was identified as a bio-retention area (he went on to explain the difference between the bio-retention and infiltration trench, Howard County soils does not support infiltration systems well), the photo below was mandated by the state and the county insured that the system was installed and constructed according to plan. The department reference above inspects (not Planning and Zoning) and property is responsible for maintenance.

I then get a call from the Illicit Discharge, a program within the Storm Water Management Division of Public Works Department , and they said they do not want to see my process wash water enter the photoed system below.(the call was prompted by my email being forward form Storm Water Management Structures)


DSC_0312.JPGDSC_0313.JPG

I really am trying to get a better understanding.
 
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.
 
Robert Hinderliter said:
I will be happy to answer questions about the interpretation of the EPA’s Cosmetic Cleaning Ordinance. Copy and paste the part you have questions about if they are not clear to you.

Also any part of the Video on pwna.org/environmental.
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I already copied and pasted your BMP Vs a normal BMP with no reference to hot water being the same as soap.

You claimed you didn't make it up.

You danced around and gave me a thousand pages to read that resulted in one area (Oregon) that has any regulation restricting hot water, and it RESTRICTED ALL powerwashing.

Yet you still haven't given any reason as to WHY you would put such language in BMP's that are you claim are to make it easier for our industry.

I have no further questions after that one. I don't have time to read another 1,000 pages on a wild goose chase when a simple straightforward answer will do.
 
Excerpts from the EPA's Model Cosmetic Cleaning Ordinance:

Cosmetic Cleaning means cleaning done for cosmetic purposes. It does not include industrial cleaning, cleaning associated with manufacturing activities, hazardous or toxic waste cleaning, or any cleaning otherwise regulated under federal, state, or local laws.

Mobile commercial cosmetic cleaning means power washing, steam cleaning, and any other mobile cosmetic cleaning operation, of vehicles and/or exterior surfaces, engaged in for commercial purposes.

Municipal separate storm sewer system (MS4) means the system of conveyances (including sidewalks, roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made
channels, or storm drains) owned and operated by the City and designed or used for collecting or conveying storm water, and which is not used for collecting or conveying sewage.

National Pollutant Discharge Elimination System (NPDES) means the national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing and enforcing pretreatment requirements, under sections 307, 402, 318, and 405 of the federal Clean Water Act.

Wastewater means any water or other liquid,otherthanuncontaminated storm water, discharged from a facility.

Water in the state means ground-water,percolating or otherwise, lakes, bays, ponds, impounding reservoirs, springs, rivers, streams, creeks, wetlands, marshes, inlets, canals inside the territorial limits of the state, and all other bodies of surface water, natural or artificial, navigable or non-navigable,and including the bed and banks of all water courses and bodies of surface water that are wholly or partially inside or bordering the state or inside the jurisdiction of the state.

For exterior cleaning, best management practices shall include, but not be limited to, the following:

(1) Accumulations of oil and grease which have not dried shall be precleaned with absorbent clay (kitty litter) or a similar material and properly disposed of prior to washing.

(2) Storm sewer entrances which will receive the washwater shall be screened to catch leaves and other debris. Wash water discharge shall comply with Section 12.5-
302(b)(15).

(3) Wash water discharged to the MS4 shall first pass through an oil absorbent boom or pad to absorb hydrocarbons so that no oil sheen is present on the discharge. Wash water discharge shall comply with Section 12.5-302(b)(15).

(4) Wash water which does not comply with Section 12.5-302(b)(15) shall be discharged into the sanitary sewer system. Discharge shall be at the job site when possible. Washwater from recycle rigs which does not comply with Section 12.5-302(b)(15) shall be disposed of in compliance with subsection (c) of this section. Grit and sludge shall not be disposed of through the sanitary sewer.

A permit holder shall not discharge wastewater into the sanitary sewer, either on a job site or off a job site, without the permission of the owner of the property upon which the sewer inlet is located.
The permit holder shall provide proof of such permission to the Director upon demand.
 
Clean County PW said:
Robert can you or anyone here get me a copy or direct me to all the footage from the Houston video's? I want to study them to start building my own "Lack of knowledge" to see how I could start getting the right people together by some type acceptable form of communication.
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John:

There are a ton of environmental videos on www.youtube.com , search on POWERWASHoCOM . About the third page down is the Houston Videos.
 
Robert Hinderliter said:
Excerpts from the EPA's Model Cosmetic Cleaning Ordinance:

Cosmetic Cleaning means cleaning done for cosmetic purposes. It does not include industrial cleaning, cleaning associated with manufacturing activities, hazardous or toxic waste cleaning, or any cleaning otherwise regulated under federal, state, or local laws.

Mobile commercial cosmetic cleaning means power washing, steam cleaning, and any other mobile cosmetic cleaning operation, of vehicles and/or exterior surfaces, engaged in for commercial purposes.

Municipal separate storm sewer system (MS4) means the system of conveyances (including sidewalks, roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made
channels, or storm drains) owned and operated by the City and designed or used for collecting or conveying storm water, and which is not used for collecting or conveying sewage.

National Pollutant Discharge Elimination System (NPDES) means the national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing and enforcing pretreatment requirements, under sections 307, 402, 318, and 405 of the federal Clean Water Act.

Wastewater means any water or other liquid,otherthanuncontaminated storm water, discharged from a facility.

Water in the state means ground-water,percolating or otherwise, lakes, bays, ponds, impounding reservoirs, springs, rivers, streams, creeks, wetlands, marshes, inlets, canals inside the territorial limits of the state, and all other bodies of surface water, natural or artificial, navigable or non-navigable,and including the bed and banks of all water courses and bodies of surface water that are wholly or partially inside or bordering the state or inside the jurisdiction of the state.

For exterior cleaning, best management practices shall include, but not be limited to, the following:

(1) Accumulations of oil and grease which have not dried shall be precleaned with absorbent clay (kitty litter) or a similar material and properly disposed of prior to washing.

(2) Storm sewer entrances which will receive the washwater shall be screened to catch leaves and other debris. Wash water discharge shall comply with Section 12.5-
302(b)(15).

(3) Wash water discharged to the MS4 shall first pass through an oil absorbent boom or pad to absorb hydrocarbons so that no oil sheen is present on the discharge. Wash water discharge shall comply with Section 12.5-302(b)(15).

(4) Wash water which does not comply with Section 12.5-302(b)(15) shall be discharged into the sanitary sewer system. Discharge shall be at the job site when possible. Washwater from recycle rigs which does not comply with Section 12.5-302(b)(15) shall be disposed of in compliance with subsection (c) of this section. Grit and sludge shall not be disposed of through the sanitary sewer.

A permit holder shall not discharge wastewater into the sanitary sewer, either on a job site or off a job site, without the permission of the owner of the property upon which the sewer inlet is located.
The permit holder shall provide proof of such permission to the Director upon demand.
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So what was wrong with this Robert? Why did you have to go and screw it up with the "emulsifier" garbage? I see no mention of hot water being the same as so@p here.

Here is and excerpt from the same source as the "waters of the state" section:

(13) "Pollutant" means dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, filter backwash, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into any water in the state.

Notice it says "heat". There is a big difference between a powerwasher putting out 6 gallons per minute and the runoff reaching ambient temperature as it travels towards it's destination and a power plant dumping a million gallons of boiling water into the lake. These regulations were made for THOSE types of discharge.

Notice it didn't say anything about filtered water but rather filter BACKWASH. This is far different from us in this industry stopping pollution with oil socks and other filtration.
 
Tony Shelton said:
So what was wrong with this Robert? Why did you have to go and screw it up with the "emulsifier" garbage? I see no mention of hot water being the same as so@p here.

Here is and excerpt from the same source as the "waters of the state" section:

(13) "Pollutant" means dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, filter backwash, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into any water in the state.

Notice it says "heat". There is a big difference between a powerwasher putting out 6 gallons per minute and the runoff reaching ambient temperature as it travels towards it's destination and a power plant dumping a million gallons of boiling water into the lake. These regulations were made for THOSE types of discharge.

Notice it didn't say anything about filtered water but rather filter BACKWASH. This is far different from us in this industry stopping pollution with oil socks and other filtration.
Click to expand...


Fort Worth FAQ's at http://fortworthtexas.gov/uploadedF...uality/Power_Washer_Permit/PowerWasherFAQ.pdf


Mobile Commercial Cosmetic Cleaning Permit
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Frequently Asked Questions
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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Why do we have a permit?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]In 1993, Environmental Management tested 560 sites within the city limits. We discovered detergents in over 50% of these sites making detergents the most frequently encountered pollutant in the city. Cosmetic cleaning is a significant source of these detergents and because the EPA is giving the city five (5) years to show a decrease in the pollutants at the 560 sites the city had to enact specific regulations for cosmetic cleaning. The City of Fort Worth’s TPDES Permit requires regulation of discharges.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]When did the "no off-property discharge" regulation go into effect?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]It has been illegal to discharge any type of wastewater off-property in Fort Worth since the turn of the century. However, the regulations had not been heavily enforced until recently so many cosmetic cleaners were under the mistaken impression that it was legal for them to discharge their wash water to the storm drain.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]What type of operation is regulated by the permit?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Under the ordinance, mobile commercial cosmetic cleaning means "power washing, steam cleaning, and any other mobile cosmetic cleaning operation, of vehicles and/or exterior surfaces, engaged in for commercial purposes." Facilities which use their own employees for power washing are not regulated. However, they still must adhere to the prohibitions of the storm water ordinance regarding discharges to the storm sewer.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Who sets the fees for the permits?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The City Council sets all fees for all programs run in the city.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Why do I have to pay a fee?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The city is allowed by law to cover all administrative costs of a specific program by charging a fee. The fee cannot be used just to make money for the Department. Your fee pays for all of the paperwork, computer data, sticker costs and labor needed to run this permit program.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Why do I need to put the numbers and stickers on my rig?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]When an inspector drives by and sees you in operation he is going to stop and observe your set up and he will need to know if you are holding a valid permit. If he sees your registration numbers and sticker on your rig, then he will not have to interrupt you and cause you to lose valuable work time by having you dig through your truck looking for your paperwork. In fact, the only time you should have to talk to an inspector is when you have a question.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]I sometimes pull the spray rig out of my truck and use it as my private vehicle. Do I have to put numbers and stickers on the outside of my truck? -or- I paid several hundred dollars for a custom paint job on my truck and trailer. Do I have to put these stickers and numbers on and ruin the look of my rig?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The answer to this is no. We do not want anyone to ruin a great paint job or make their vehicle look like strictly a business truck. You can place the numbers and stickers anywhere you wish as long as they are visible. For instance, you could place them on the water tank or somewhere on the side of the spray rig. You could also place them on some sort of placard that could be removed when you are not using your truck for business purposes.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Will private citizens washing cars in their driveways be required to obtain a permit? After all, their wash water is entering the streets and storm drains.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The EPA has exempted residential car washing from the storm water rules so private citizens do not need any sort of permit. However, the city does recognize this activity as another source of detergents that enter our waterways and encourages residents to consider alternative car washing methods. The Environmental Management and the Water Department distribute this information through brochures, newspaper articles, water bill inserts, programs to neighborhood associations, classroom lectures and a host of other public education activities.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]I use biodegradable detergents. Why can't I discharge these to the storm drain?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The term "biodegradable" simply means that the product will not harm bacteria in the sewage treatment plant, and that it breaks down faster than more conventional products. A biodegradable detergent can cause a fish kill in a creek just as fast as any other type of detergent. We do appreciate the use of biodegradable products because they are much gentler on the treatment plant when you properly dispose of them to the sanitary sewer.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Do I need to test my water if I am not using a recycling rig?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]No. However, all limitations that are associated with discharges to the sanitary sewer do apply to you and you could be fined by the Water Department for exceeding these limitations. You should always be aware of what you are discharging to the sanitary sewer and take all necessary precautions needed to keep your discharge as clean as possible.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Do I need to supply a map of my discharge points if I don't use a wash water recycling unit?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]No. This is only required of those using recycling units because the Water Department must have a method of monitoring these points to comply with EPA regulations.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]May I wash a parking lot or gas station with cold (or hot) water only and discharge it to the storm drain?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Probably not. Even though the ordinance states that you can discharge to the storm drain if you don’t use detergents, degreasers, etc., you will probably be washing oil, grease, metals and dirt off property which will violate the ordinance. This exemption was designed for cosmetic cleaners washing objects such as sidewalks, headstones, walls and other things that are unlikely to be affected by the normal pollutants. Remember, it is not just the chemicals you use; it is also the pollutants you wash off that are banned from the storm drain system.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Is dirt considered a pollutant?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Dirt itself is not considered a true pollutant. However, the State of Texas does have a numerical standard for discharges of dirt to waterways. This standard is known as Total Suspended Solids (TSS). So even if you are not washing pollutants off property and you are allowed to discharge to the storm drain, be aware that too much dirt will put you in violation of the TSS Standard and you could be fined by the city and the state.

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]How do I access the sanitary sewer line to properly dispose of my wash water?

[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]You can access the line through a clean out stub (where the plumber sends the drain snake), a sink, a toilet or some floor drains. Be aware that most floor drains located outside go to the storm sewer rather than the sanitary sewer, so be sure you know how things are plumbed before discharging to floor drains. If there is a car wash or some sort of sand or grit trap on the property, discharge into those as they will help clean your wash water before it enters the pipe. Never open a manhole. Opening manholes is not only extremely dangerous; it is also against the law
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Duplicate, Will some one fix this?
 
Whats that word? William


Like asking Ken fenner a Financial question and referencing Forbes
Tony Shelton said:
This is like asking what the second commandment says and getting a post of the whole bible as the answer.

Good grief!

Sent from my DROID RAZR using Tapatalk 2
Click to expand...
 
Tony Shelton said:
So what was wrong with this Robert? Why did you have to go and screw it up with the "emulsifier" garbage? I see no mention of hot water being the same as so@p here.

Here is and excerpt from the same source as the "waters of the state" section:

(13) "Pollutant" means dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, filter backwash, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into any water in the state.

Notice it says "heat". There is a big difference between a powerwasher putting out 6 gallons per minute and the runoff reaching ambient temperature as it travels towards it's destination and a power plant dumping a million gallons of boiling water into the lake. These regulations were made for THOSE types of discharge.

Notice it didn't say anything about filtered water but rather filter BACKWASH. This is far different from us in this industry stopping pollution with oil socks and other filtration.
Click to expand...

http://fortworthtexas.gov/uploadedF...uality/Power_Washer_Permit/PowerWasherBMP.pdf

Criminal penalty for illicit discharge

A person commits an offense, punishable by a fine of up to $2,000 per day per offense, if he introduces or causes to be introduced any discharge to the storm drain system that is not composed entirely of stormwater.

There are some defenses to this rule, including runoff from lawn sprinklers, surfacing groundwater and fire fighting water.

Cosmetic cleaners may use the following defense:



Claim that discharge or flow from cold water used in cosmetic cleaning is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance.


This defense also applies to discharges using hot water cosmetic cleaning without any of the mentioned contaminants provided that permission is granted by Environmental Management prior to using the hot water. Hot water is defined as any water over 110°F. Remember, any discharge must be screened for debris and must pass through an oil boom or oil absorbent pad before it enters the storm drain system.
 
You forgot to post Jail Time Robert
Robert Hinderliter said:
http://fortworthtexas.gov/uploadedF...uality/Power_Washer_Permit/PowerWasherBMP.pdf

Criminal penalty for illicit discharge

A person commits an offense, punishable by a fine of up to $2,000 per day per offense, if he introduces or causes to be introduced any discharge to the storm drain system that is not composed entirely of stormwater.

There are some defenses to this rule, including runoff from lawn sprinklers, surfacing groundwater and fire fighting water.

Cosmetic cleaners may use the following defense:



Claim that discharge or flow from cold water used in cosmetic cleaning is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant or any other cleaning substance.


This defense also applies to discharges using hot water cosmetic cleaning without any of the mentioned contaminants provided that permission is granted by Environmental Management prior to using the hot water. Hot water is defined as any water over 110°F. Remember, any discharge must be screened for debris and must pass through an oil boom or oil absorbent pad before it enters the storm drain system.
Click to expand...
 
Tony Shelton said:
So what was wrong with this Robert? Why did you have to go and screw it up with the "emulsifier" garbage? I see no mention of hot water being the same as so@p here.

Here is and excerpt from the same source as the "waters of the state" section:

(13) "Pollutant" means dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, filter backwash, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into any water in the state.

Notice it says "heat". There is a big difference between a powerwasher putting out 6 gallons per minute and the runoff reaching ambient temperature as it travels towards it's destination and a power plant dumping a million gallons of boiling water into the lake. These regulations were made for THOSE types of discharge.

Notice it didn't say anything about filtered water but rather filter BACKWASH. This is far different from us in this industry stopping pollution with oil socks and other filtration.
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Tony:

I did not write everything in that document, no single person did. It was a result of a group effort of several organizations and many people reviewed it and made changes. I was the Chairman of the committee.

I personally did not create that statement, and do not remember who did. My version was deemed to technical and a lot of it was reworded for easier understanding. Coming from a technical background I know the statement is technically correct, so I did not challenge it.

One of the things I learned was that the regulations are written in legalese , then there is an explanation of what they mean in layman’s terms.

If you read a lot of regulations you will find that is how things are implemented.

My writing style was considered too technical by a majority of the committee.

Sorry.
 
Tony:

This is more technical version, which I prefered but was rejected.
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