EPA Enforcement in 2012 Protects Communities From Harmful Pollution

My intention is not to be absurd or to make intellectually dishonest suggestions.

My comments are based on supplied information by AHJ's and design engineers of similar systems and even more advanced units within the same state but different locals.

Tony it may handle what you speak of, but on the few I have inquired about, I was advised that it would be considered a violation to be utilized for other than what it was intended.

Please post the data supplied to you by the design engineers that support your claim.



Sent from my Transformer TF101 using Tapatalk 2
 
Please post the data supplied to you by the design engineers that support your claim.



Sent from my Transformer TF101 using Tapatalk 2


I spoke with this representative of the storm system:

John Brown
Customer Solutions Coordinator-Maintenance
CONTECH Construction Products Inc.
605 Global Way Suite 113 | Linthicum, MD 21090
Office: 410-796-5505 Ext. 1519 | Fax: 866-376-8511




and from my county

http://www.co.ho.md.us/DisplayPrimary.aspx?ekfrm=530
 
No storm water guy is ever going to tell you discharging off property will be ok. Keep in Mind the most responsible method as Taught by the storm water authorities over and over at National Cleaning Expo. " No OFF property Discharge"
I spoke with this representative of the storm system:

John Brown
Customer Solutions Coordinator-Maintenance
CONTECH Construction Products Inc.
605 Global Way Suite 113 | Linthicum, MD 21090
Office: 410-796-5505 Ext. 1519 | Fax: 866-376-8511




and from my county

http://www.co.ho.md.us/DisplayPrimary.aspx?ekfrm=530
 
No storm water guy is ever going to tell you discharging off property will be ok. Keep in Mind the most responsible method as Taught by the storm water authorities over and over at National Cleaning Expo. " No OFF property Discharge"


This county authority does not even want to hear of per-treatment and discharge to sanitary.

Thats why it was such a milestone for Prince Georges and Montgomery Counties Maryland, after almost two and a half years of communicating with the AHJ's of the POTW's we finally have BMP's to discharge our wash water after pre-treatment to sanitary sewer of the property.

The City of Knoxville was even more open to pre-treatmnet and discharge vs my own Howard County
 
Here's the reality, my wash Process create no pollution. I reduce pollution existing in the contained environment. The minute I start practicing the fundamental principals of a BMP, sweep and collect Large Debris. I have reduced Pollution, take it another step if there are large amounts of contaminates use and absorbent prior to wash process.

I'm ready to begin my contained wash on this compliant property, next I look to see where I can use and absorbent sock or other device to allow the stream of water to further collect any existing pollution that already existed on this site. I'm further continuing to reduce pollution on this property through the entire wash process. If my water get to the collect system built on this property I could claim I reduced the pollution thats was already existing substantially prior to any rain event.

I used the most responsible method at least six water authorities regulators have deemed to be the most responsible. Hauling or using sanitary was not intended by design, every property owner is responsible for there own discharge, property are suppose to handle any rain event. There for the out-fall should not happen until the water has been filtered by there system if there is any. As the Educator mentions in this video man made Ponds are made to retain the water permanently.

Please understand this has nothing to do with Discharging into the MS4


Robert you have been or rep to this industry for about 10 years, I have been following You since 1996. I would say Lance, Kendra & a Gal from California who now herself is out of business.

These people have the same thing in common with the distributor in Houston that was pushing strict guidelines, they are all out of business.

Robert if you use the words responsible you need to talk first about containment. never entering the MS4, you will never because I have asked you many times over the years. I remember explaining it to you years ago and I know you understand and you get it.

Having Pressure washers hauling Waste water will never be a practical responsible method, Houston didn't this so.

Next all these people you are posting as violators have often millions of gallons of waste water, it doesn't compare even If I did ad contaminants to my wash process, which by the way i do not.
 
Tony Shelton I should have mentioned your name as well as one of the guys who post on PWI that has a ton of knowledge on environmental cleaning as well.

Since you do alot of reading and studying up on this topic and of course dealing with it out in the streets.. I'm curious if your going to rebut what Nigel posted since Nigel was told this by his local Storm system representative and also gives the persons name.

Because some may not agree with this spokesperson does it make it right let's say in Nigel's area to do do the cleaning the way we say it's right? Is that the direction this this thread will end up going do you think?

I'm interested to see what you would suggest Nigel should do since he was given his information.
 
Nor do ours, that was my devils Advocate Thread why didn't they do it. Here's what your not embracing, just do your best to clean whats existing on property. Do not allow your customers to create pollution, neglect of handing this more frequent is not and excuse either.

Sanitary is discharging it off property, long ago industrial sites delivered this waste to the city. The Clean water act is about no off property Discharge, Larger corporations had to start pretreating there own waste water prior to discharge off property. We do not fit into this category, we do not create waste. We only are reducers of pollution.


Try talking to them differently, stop talking about this pollution you did not create but are cleaning up. ( Inside a contained area- Private property) Your local authorities have no jurisdiction over you unless you pose a threat. If you do not pose a threat they have no probable cause to enter the property. You might say well if I turn my machine on they would, in that case when it rains they should be over there handing citations to the owner of the rain water running off the property. Every property owner is responsible for there discharge if its happening. They would be the first sited....by your authorities as they are the largest violators and major offenders.

This takes me back to Houston when I asked them why they have properties connected, they didn't have and answer. I asked lets go round up all the developers the building and Zoning manager and charge them all.


This county authority does not even want to hear of per-treatment and discharge to sanitary.

Thats why it was such a milestone for Prince Georges and Montgomery Counties Maryland, after almost two and a half years of communicating with the AHJ's of the POTW's we finally have BMP's to discharge our wash water after pre-treatment to sanitary sewer of the property.

The City of Knoxville was even more open to pre-treatmnet and discharge vs my own Howard County
 
Here's the reality, my wash Process create no pollution. I reduce pollution existing in the contained environment. The minute I start practicing the fundamental principals of a BMP, sweep and collect Large Debris. I have reduced Pollution, take it another step if there are large amounts of contaminates use and absorbent prior to wash process.

I'm ready to begin my contained wash on this compliant property, next I look to see where I can use and absorbent sock or other device to allow the stream of water to further collect any existing pollution that already existed on this site. I'm further continuing to reduce pollution on this property through the entire wash process. If my water get to the collect system built on this property I could claim I reduced the pollution thats was already existing substantially prior to any rain event.

I used the most responsible method at least six water authorities regulators have deemed to be the most responsible. Hauling or using sanitary was not intended by design, every property owner is responsible for there own discharge, property are suppose to handle any rain event. There for the out-fall should not happen until the water has been filtered by there system if there is any. As the Educator mentions in this video man made Ponds are made to retain the water permanently.

Please understand this has nothing to do with Discharging into the MS4


Robert you have been or rep to this industry for about 10 years, I have been following You since 1996. I would say Lance, Kendra & a Gal from California who now herself is out of business.

These people have the same thing in common with the distributor in Houston that was pushing strict guidelines, they are all out of business.

Robert if you use the words responsible you need to talk first about containment. never entering the MS4, you will never because I have asked you many times over the years. I remember explaining it to you years ago and I know you understand and you get it.

Having Pressure washers hauling Waste water will never be a practical responsible method, Houston didn't this so.

Next all these people you are posting as violators have often millions of gallons of waste water, it doesn't compare even If I did ad contaminants to my wash process, which by the way i do not.
good post Ron.. I'll ask Robert myself again which I do believe I asked him this very question as well in the past. He post some of the stuff he does because these companies and circumstances he sometimes writes about are at the "top of the food chain" of companies that get hit with violations. These have a way to trickle down to what some people including prop. Management companies think about our services at times which is at the bottom of their list of importance-- us Powerwashers.

Robert makes us aware of this and where it starts from at times... At least that's my take on it. I'll have to ask him again since as I get older these challenges do become more interesting to me.

So Ron-- question for you.. What do you suggest for guys that do parking garages on how they should handle the massive sludge issues we run into and do we take that off of premises if the property doesn't have a place to dispose of it?
 
Tony Shelton I should have mentioned your name as well as one of the guys who post on PWI that has a ton of knowledge on environmental cleaning as well.

Since you do alot of reading and studying up on this topic and of course dealing with it out in the streets.. I'm curious if your going to rebut what Nigel posted since Nigel was told this by his local Storm system representative and also gives the persons name.

Because some may not agree with this spokesperson does it make it right let's say in Nigel's area to do do the cleaning the way we say it's right? Is that the direction this this thread will end up going do you think?

I'm interested to see what you would suggest Nigel should do since he was given his information.


John, stop referring PWI guys please. I do not represent PWI nor does Tony, this BBS is the entire industry. I can tell you this is that people are getting education, maybe you one day will open your eyes and understand that Roberts methods in the MS4 might be good. Its just not needed 90% of the time, this is the message we need to get out.

We all need to stop talking about Discharging waste
 
good post Ron.. I'll ask Robert myself again which I do believe I asked him this very question as well in the past. He post some of the stuff he does because these companies and circumstances he sometimes writes about are at the "top of the food chain" of companies that get hit with violations. These have a way to trickle down to what some people including prop. Management companies think about our services at times which is at the bottom of their list of importance-- us Powerwashers.

Robert makes us aware of this and where it starts from at times... At least that's my take on it. I'll have to ask him again since as I get older these challenges do become more interesting to me.

So Ron-- question for you.. What do you suggest for guys that do parking garages on how they should handle the massive sludge issues we run into and do we take that off of premises if the property doesn't have a place to dispose of it?

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.
 
I can tell you this is that people are getting education, maybe you one day will open your eyes and understand that Roberts methods in the MS4 might be good. Its just not needed 90% of the time, this is the message we need to get out.

waste
I understand about the 90% factor. I would say from my experiences that's an accurate percentage. It's that 10% factor I need to learn more about because I think my business direction is going to head towards that if I dive even further into parking garage cleaning where a deeper cleaning may bring in more nasty runoff and sludge. Also at the end of this spectrum could be some more intricate Cleanings that aren't discussed much on these bulletin boards.. I'm not alluding to "Waste management" because we all know what that is in my area...lol
 
I understand about the 90% factor. I would say from my experiences that's an accurate percentage. It's that 10% factor I need to learn more about because I think my business direction is going to head towards that if I dive even further into parking garage cleaning where a deeper cleaning may bring in more nasty runoff and sludge. Also at the end of this spectrum could be some more intricate Cleanings that aren't discussed much on these bulletin boards.. I'm not alluding to "Waste management" because we all know what that is in my area...lol

Any building and Zoning we have talked has been nothing less than 15% Maryland being 96% and the leader.

Even Houston has a Site to show you what propertys are connected and not. Yet the enforcement was not aware and did not use it in there police work.

Houston was 85% compliant in the Metro area of that building dept. The rule was owner change or renovation they had to comply with New CWA rules. ( this is all based on Acres on commercial only.) residential we did not talk about.
 
I spoke with this representative of the storm system:

John Brown
Customer Solutions Coordinator-Maintenance
CONTECH Construction Products Inc.
605 Global Way Suite 113 | Linthicum, MD 21090
Office: 410-796-5505 Ext. 1519 | Fax: 866-376-8511




and from my county

http://www.co.ho.md.us/DisplayPrimary.aspx?ekfrm=530


So, Nigel, if I understand this correctly, you are saying that John Brown, from Contech Construction Products, Inc, told you on the phone that his products are so ineffective that they cannot handle runoff from a properly pre-swept and drycleaned, then deep cleaned Fuel pad? But rather, can only handle the occasional rain event?

I have screenshot this thread and will be sending it to him and his boss, Mr. Keating, on Monday to verify these claims.

Anybody can make anybody say anything on the phone. I could ask "Is your system designed to deal with hundreds of gallons of gasoline and oil runoff while cleaning pads?" The obvious answer would be no.

But the question is deceptive. We may be dealing with a few hundred gallons of water, but the actual oil and gasoline content is only a tiny fraction of those gallons.

It would be like calling and asking voters "Are you going to vote for Mitt Romney or that muslim guy wants to kill you if you don't convert to Islam.

As for the second part, The local water authority is the LAST place to find accurate information about any water filtration system. They are bombarded daily with a hundred guys like Robert who have "the best system" according to them. Most of them, like Robert, love to wrap the authorities around their fingers so that they can "shop" BMP's or rules that require contractors to use their products. Thankfully, most of the AHJ's, like mine here in Las Vegas already know this and laugh about them behind the scenes.

Further, the local authorities don't want to deal with any runoff issues at all. Asking them about the abilities of a commercially available detention system is like asking PETA (the people for ethical treatment of animals) what are the kill shot capabilities of a 30-06 at 200 yards.

You seem to be so infatuated with fuel pads why have you not dissected what is actually in the runoff before filtration to find out exactly what kind of filtration you need. In other words, we have no cottonwood here in Las Vegas. It would be stupid (and completely dishonest) of me to sell my customers cottonwood filters for their condensers.

How do you know what is needed to filter this waste if you don't even know what is in it and in what concentrations?
 
Any building and Zoning we have talked has been nothing less than 15% Maryland being 96% and the leader.

Even Houston has a Site to show you what propertys are connected and not. Yet the enforcement was not aware and did not use it in there police work.

Houston was 85% compliant in the Metro area of that building dept. The rule was owner change or renovation they had to comply with New CWA rules. ( this is all based on Acres on commercial only.) residential we did not talk about.

Interesting and informative. Since Houston is 85% compliant with the building dep't and some contractor happens to get cited for cleaning one of the 15% that aren't compliant with the building Dep't can the contractor be held responsible at all here?

Also how do I found out how Compliant certain area's in NY are with the building Dept's of those area's. Do I walk in there and tell them the place I plan on cleaning to see if there in compliance or do all areas have a site map that shows the up to date info on it? How do you search for that site? Also what happens if you find out the place your going to clean is not in compliance with the Bldg Dep't. What would be your suggestion there?
 
Interesting and informative. Since Houston is 85% compliant with the building dep't and some contractor happens to get cited for cleaning one of the 15% that aren't compliant with the building Dep't can the contractor be held responsible at all here?

Also how do I found out how Compliant certain area's in NY are with the building Dept's of those area's. Do I walk in there and tell them the place I plan on cleaning to see if there in compliance or do all areas have a site map that shows the up to date info on it? How do you search for that site? Also what happens if you find out the place your going to clean is not in compliance with the Bldg Dep't. What would be your suggestion there?

John I have a Video of a NEw york authority I called on for a local contractor in Long Island , let me find it.

http://www.youtube.com/watch?v=4uuA3J1opPQ


They will site for not cleaning the walks

http://www.youtube.com/watch?v=Y0qXmONO7nU

This guy was a New yorker for sure
 
Other industries have found perfectly legal ways to filter runoff without the use of complicated pumping or vacuuming machines that require more use of small engines pumping exhaust into the air.

Failing to push for simple gravity filtration and the full implementation of the built-in systems that already exist to deal with rainwater runoff such as detention basins and nature filtered areas is treason to our industry.

Our industry is LOW IMPACT with a NET POSITIVE effect on the environment. We are not polluters. We are cleaners.

What's next when vacuums, bulky filter systems and sump pumps fail to bring in enough revenue?.....A campaign against the very small engines that run them? I can hear it now:

"Get rid of all small engines.........Don't IMPAIR the AIR".

This is ridiculous.

The entire approach is flawed as proven by the march down to Houston to bend over, pull down our pants and say "Do what you like, regulators, just tell us what you want us to do".

Thank God for Ron educating them on the fact that retention systems exist and were built for a reason, allowing Houston contractors to get back to work.

No other industry on the planet would allow one of their own to lay down and make policy that confuses it's own contractors and the public.

And an industry org that would allow it would be blackballed.

It's appalling.

Tonly: Please show these "Perfect Legal Ways" you are talking about. This would be valuable to eveyone on this Forum.

Everyone needs to know the least expensive way to comply.

Thanks,
 
Tonly: Please show these "Perfect Legal Ways" you are talking about. This would be valuable to eveyone on this Forum.

Everyone needs to know the least expensive way to comply.

Thanks,

Robert, if you are willing to take a serious look at the direction we are taking our industry in this regard I am more than willing to bring up examples of other industries.

I have quite a few of them, but we an address them individually starting with the construction industry.

I know the little catch-phrase "nothing down the drain but r@in" sounds great. But that is not, in fact, how it works in reality. If "nothing" was allowed down the drain but r@in, then there would be no need for NPDES permits because nothing would be permitted.

The first industry we can discuss is the construction industry.

How many construction sites have you seen with vacuum systems and large filter systems set up to treat runoff prior to the storm drain? That's right, they don't exist. A construction site is a TEMPORARY and potentially HIGH IMPACT zone, yet they are ALLOWED to let gravity filtered runoff enter the storm drain, whether that runoff is the result of a storm or if it is incidental to the work, i.e. dust control, vehicle wash without soap, etc. They are allowed this because the law states that contaminants be reduced to the GREATEST EXTENT PRACTICABLE. That means if is isn't cost effective or if it doesn't make sense to build gigantic filtering systems onsite, then it is not to be required.

Mobile contract cleaners are also TEMPORARY in their time onsite. But we are a LOW IMPACT industry using the power of pressure to clean rather than high volumes of water with the exception of your colleague and fellow PWNA chair, Mr. Gamble who likes to GAMBLE with the fire equipment and use a fire hose for rinsing to make more profit.

If the construction orgs could come up with something reasonable, simple, inexpensive and sensible for their members, then why haven't you done the same for us?

Here is the BMP for the California Stormwater Quality Association.

http://www.cabmphandbooks.com/Documents/Construction/SE-10.pdf

And also, if the authorities themselves are using gravity filtration to deal with all contaminants during the massive flow of a storm, then why in the world have we not been working on convincing them for the past 15 years that we, too, can deal with runoff using the same layers of filtration to deal with a measly 5-11 gallons per minute while cleaning?????

http://www.cabmphandbooks.com/Documents/Development/TC-40.pdf

Thank you.
 
My answers in green.




Nor do ours, that was my devils Advocate Thread why didn't they do it. Here's what your not embracing, just do your best to clean whats existing on property. Do not allow your customers to create pollution, neglect of handing this more frequent is not and excuse either.

I do my best to clean what is existing on the property, but in doing so with pressure cleaning (even after practicing BMP's of dry clean up) I generate water that is now soiled, sometimes enough that it becomes a challenge to leave on property, without it escaping to area that I do not want it to go.

Sanitary is discharging it off property, long ago industrial sites delivered this waste to the city. The Clean water act is about no off property Discharge, Larger corporations had to start pretreating there own waste water prior to discharge off property. We do not fit into this category, we do not create waste. We only are reducers of pollution.

​I agree sanitary discharge is off property.

Some of the POTW's do not want to classify the type of pressure cleaning we provide into the category of "industrial discharge" and this would be awesome. This is what we collectively as pressure cleaners should be ensuring does not happen.

Lets look at an analogy of sweeping, I understand that sweeping activity does not created waste (**), ....in that its on the property and it would be collected and disposed of in a dumpster on the property, however it
eventually makes it off property to the landfill.

(**)A problem could arise in the process of sweeping that may send some of the product being collected in the air. Thus the sweeping machines have air filters to minimize or reduce this release in the atmosphere.

With pressure cleaning we use the medium water to dissolve and dislodge the "trash" on a surface, we want to dispose of the resulting collection from pressure cleaning like we do when sweeping, since there is usually now soiled water dumpster on site for 3rd party to remove it, lets get it to the "soiled water landfill" the "water treatment plant".



Try talking to them differently, stop talking about this pollution you did not create but are cleaning up. ( Inside a contained area- Private property) Your local authorities have no jurisdiction over you unless you pose a threat. If you do not pose a threat they have no probable cause to enter the property. You might say well if I turn my machine on they would, in that case when it rains they should be over there handing citations to the owner of the rain water running off the property. Every property owner is responsible for there discharge if its happening. They would be the first sited....by your authorities as they are the largest violators and major offenders.


I dont say anything about pollution I create when communicating with the AHJ, however some of the authorities and citizens are often curious as to were the soiled water is going.

I can imagine the AHJ's are communicating with property owners/occupants after rain events for violations as a result of inspections or citizen reports.


This takes me back to Houston when I asked them why they have properties connected, they didn't have and answer. I asked lets go round up all the developers the building and Zoning manager and charge them all.
 
My answers in green. I hope viewers understand that this was written in a calm tone, the written word is not always the best sole form of expression.



So, Nigel, if I understand this correctly, you are saying that John Brown, from Contech Construction Products, Inc, told you on the phone that his products are so ineffective that they cannot handle runoff from a properly pre-swept and drycleaned, then deep cleaned Fuel pad? But rather, can only handle the occasional rain event?


Tony you read what I wrote, when you speak with John B, if he needs a refresher , ask him to reference his emails on the 08/14/12


I have screenshot this thread and will be sending it to him and his boss, Mr. Keating, on Monday to verify these claims.


I expected nothing less

Anybody can make anybody say anything on the phone. I could ask "Is your system designed to deal with hundreds of gallons of gasoline and oil runoff while cleaning pads?" The obvious answer would be no.


Are you aware of my system?

How do you handle the "soiled water" from the described cleaning?


But the question is deceptive. We may be dealing with a few hundred gallons of water, but the actual oil and gasoline content is only a tiny fraction of those gallons.

What question is deceptive?

To the best of my recollection the questions posed to John B was:

I would like some information on a product that was installed on a property ,(he provided the design drawings), I then when on to explain that I am about to pressure clean the fueling pad and walks, can I direct the "wash water" to this installation for such activity?

You can inform all of us what his current response is.


The other issue was the outlet of that installation lead off property to a storm pond.

It would be like calling and asking voters "Are you going to vote for Mitt Romney or that muslim guy wants to kill you if you don't convert to Islam.

As for the second part, The local water authority is the LAST place to find accurate information about any water filtration system. They are bombarded daily with a hundred guys like Robert who have "the best system" according to them. Most of them, like Robert, love to wrap the authorities around their fingers so that they can "shop" BMP's or rules that require contractors to use their products. Thankfully, most of the AHJ's, like mine here in Las Vegas already know this and laugh about them behind the scenes.


Surprising the local water authority of that jurisdiction had accurate information.

I was told the calls that department often receives are from concerned citizens about illicit discharge. That local authority took matters very seriously and investigated a pressure cleaning contractor operation sometime recently prior to my call.


Further, the local authorities don't want to deal with any runoff issues at all. Asking them about the abilities of a commercially available detention system is like asking PETA (the people for ethical treatment of animals) what are the kill shot capabilities of a 30-06 at 200 yards.


Like I said it was just the opposite of your experience with my local authorities.


You seem to be so infatuated with fuel pads why have you not dissected what is actually in the runoff before filtration to find out exactly what kind of filtration you need. In other words, we have no cottonwood here in Las Vegas. It would be stupid (and completely dishonest) of me to sell my customers cottonwood filters for their condensers.

I am not infatuated with fuel pads, it is something I have been interested in cleaning and have been asked to clean.

I have attempted to "dissect" the soiled water believe it or not, in the interim I have made what I believe to be educated summation of what the "runoff" contains, and hence identified some forms of filtration that reduces concentration of the initial contents in an attempt to comply with the pre-treatment requirements for sanitary discharge.

I will attempt again to have it scientifically analyzed, would you be interested in doing the same for a similar cleaning?

We both know the runoff would vary greatly on a host of factors, a few factors would be the initial type and quantity of ingredient, method of cleaning, detergents, etc etc


How do you know what is needed to filter this waste if you don't even know what is in it and in what concentrations?
 
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