EPA Enforcement in 2012 Protects Communities From Harmful Pollution

It's a shame that two grown men in this thread have to cut each other down and try to belittle one another. If you guys want to cutthroat each other why don't you do it on the phone or by PM. I enjoy reading these threads because of the info given. Very informative. Keep it professional and let the children play childish games. I really do appreciate everyone sharing their work experiences and knowledge they have gained from those experiences, but please don't make everyone else suffer the BS because you guys don't like each other!

I hope I have not come across as "cutting each other down", that was not my intention, I have written to the best of my recollection, provided what I believe was factually and made all attempts to be respectful as possible in the thread.

I agree some of this could have been discussed in private, I do not harbor dislike for anyone here.

I will not continue to comment further in this thread.

If anyone would like their questions answered call me on my cell
 
Figures.... You get asked a couple of tough questions and you fold your cards. You make it clear that distributors should not be involved in any decisions that affect Contractors. You have been saying that for years. Now you have a distributor here that will make decisions can and will affect contractors. For one if he does a good job and gives a hoot it doesn't matter to me. Same goes in the outside world. How about you?

You also make a statement that you have a system that's excellent for sludge. So if it works as good as you say it is then it must do a good job separating the sludge out. What do you recommend to do with all that sludge now?

I am not folding anything John. There's just no more use trying to get you to understand that Doug is Contractor who sells some chemical on the side. If you can't understand the difference between Doug and Robert, for example, there's no use trying to converse any further on it.

As far as the sludge goes I know for a fact what I have used in the past will work fine for any sludge left after cleaning a restaurant or to pick up any puddled water that is dammed when you are ready to leave the location, but I have never cleaned a garage, and don't plan to. But the product results in an instantly dry substance that can be immediately put in a dumpster on the property. It will not reduce the amount of sludge, you would need a dewatering machine for that, so it may not be the best for something like a garage.
 
I hope I have not come across as "cutting each other down", that was not my intention, I have written to the best of my recollection, provided what I believe was factually and made all attempts to be respectful as possible in the thread.

I agree some of this could have been discussed in private, I do not harbor dislike for anyone here.

I will not continue to comment further in this thread.

If anyone would like their questions answered call me on my cell


See, gentlemen, this is how nothing ever gets accomplished here. This is why we have never been able to work together to form solutions. Someone always wants to take it "private" where the conversations degenerate into nothing and nothing can ever be accomplished.
 
I hope I have not come across as "cutting each other down", that was not my intention, I have written to the best of my recollection, provided what I believe was factually and made all attempts to be respectful as possible in the thread.

I agree some of this could have been discussed in private, I do not harbor dislike for anyone here.

I will not continue to comment further in this thread.

If anyone would like their questions answered call me on my cell

Nigel. You have done and admirable job answering all questions posed to you. As has Tony. I personally am sitting back and learning from both of you. I never took any comments either of you said other than good professional debate. Which is what we need.


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I wish I had a way to have massive amounts of sludge dry when where done. That's what I thought you were holding back on that you had a way for that to be done on a grand scale. I'll keep searching since I now have a way to catch the sludge with Roberts MultiTech system. I'd say it's around 25% garages that we deal with have a designated area with a dumpster that we can unload the sludge. The other garages we have to take it out like it's trash and have it disposed of.

For now that's done by using heavy duty contractor trash bags that we dump the sludge in when we leave a floor finished. This is something I'm going to look into as well to find a better solution because these garages want the garbage and sludge removed.
 
See, gentlemen, this is how nothing ever gets accomplished here. This is why we have never been able to work together to form solutions. Someone always wants to take it "private" where the conversations degenerate into nothing and nothing can ever be accomplished.


Well that did not happen, as per our conversation for over an hour, we both were able to identify what each of us are experiencing with our own AHJ's, and we are doing our best to work with them to implement "practical" solutions for our operations, though we still had some differences of opinion in some areas, but we learned many things from each other in our conversation.
 
Nigel is dealing with an AHJ that looks at us as polluters. That is the uphill battle that we face after allowing our leaders to paint us as polluters instead of cleaners.

Nigel has been told by these same people who have painted us as polluters that we are past the point of changing anything and our only option is the potw.
The only problem, as Nigel has found out, is the potw doesn't want our runoff. And if you think the various storm water authorities were hard to work with wait till you try to deal with the umpteen thousand potw's across the nation.

At thus point, with the misinformation Nigel's AHJ has, he has turned to the potw as the only practical solution.

This is exactly why we should educate them the way Ron educated them in Houston.



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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.

Bump.

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How do you handle this Waste, The one video shows you dumping this into a Bucket outside containment polluting and contaminating ground water supply possibly.

So how do you dispose of properly?

The product in bucket was filtered through 150 to 100 oil absorbing bag filter, the bag then squeezed, water placed in sanitary , sediment to trash
 
I am not folding anything John. There's just no more use trying to get you to understand that Doug is Contractor who sells some chemical on the side. If you can't understand the difference between Doug and Robert, for example, there's no use trying to converse any further on it.

As far as the sludge goes I know for a fact what I have used in the past will work fine for any sludge left after cleaning a restaurant or to pick up any puddled water that is dammed when you are ready to leave the location, but I have never cleaned a garage, and don't plan to. But the product results in an instantly dry substance that can be immediately put in a dumpster on the property. It will not reduce the amount of sludge, you would need a dewatering machine for that, so it may not be the best for something like a garage.

Tony:

As relayed to me my an AHJ:

The sludge that goes into the dumpster should pass the paint filter test. In layman's terms that means if you put the sand into a cone paint filter then no water should drop out the bottom.

This is about like sand on a beach, if you pick up a handful and squeeze no water come out, but it is still damp; will not leach out waste water to contaminate the ground water supply.
 
Tony:

As relayed to me my an AHJ:

The sludge that goes into the dumpster should pass the paint filter test. In layman's terms that means if you put the sand into a cone paint filter then no water should drop out the bottom.

This is about like sand on a beach, if you pick up a handful and squeeze no water come out, but it is still damp; will not leach out waste water to contaminate the ground water supply.

That is why I was wondering how the garage cleaners get away with putting it in garbage bags.

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I only have one response , the off property discharge by the licensed solid waste hauler is legal. Therefore in compliance with government regulations. If I can practice this I'm doing what's right. Hauling waste to any place other than pretreatment by a licensed hauler is the only legal way. I don't care who you are or what state you reside. Take sludge off property without proper documentation and you could be far more criminally prosecuted than if you had left it.





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Ron:

This is the way an AHJ Explained it to me.

You can haul Hazardous Waste you generate to a Hazardous Waste Disposal Site, you have to sign documentation that you were the Generator. Your vehicle for hauling the waste has to meet DOT Requirements.

If you haul Hazardous Waste and you were not the generator, then you have to be licensed and meet tougher DOT Requirements. All loads Manifested.

i.e. You can haul wash water you generate, but not wash water you do not generate.
 
That is why I was wondering how the garage cleaners get away with putting it in garbage bags.

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There's better ways to remove sludge from the parking garages but at this time that's the most affordable way for me to remove it the take it to my dumps and pay per Lb to dispose of it. Best case scenario is what we used a few weeks ago, A bobcat and a designated dumpster... The garages here want the sludge removed and do not want to see you trying to stuff it down there drains...
 
Robert, a couple of years ago I asked Michael to give me access to the testing you did on runoff water. Michael told me that the only testing you had ever done was on fleet wash runoff. Now, after a few years of saying it, you've proven that I tell the truth in these matters.

Armed with fleet wash runoff data you have been "shopping" Bmp's for the entire powerwashing industry as if we all wash fleets. My son cleans major, dumpster sized, grease spills for a large Biodiesel company. Would it be fair to take data from that runoff and try to impose BMP's on guys cleaning roofs??????

Yes, Robert, most everything does come down to politics. You have been operating as a moderate when we needed a hawk. Please change your course on this asap and start fighting for us. We are cleaners, not polluters. We can easily filter on the ground and go about our business making money at a fair rate without adding additional costs in order to raise rates and rape our customers.

Please use your experience to help us.

Tony:

Please read these reports then remake the above statements, they need correcting. Michael told you the truth, he was only involved in Fleets at the time, he was too busy building his business to over 100 employees and did not have the time to follow my activities.

He is still over 80% Contract Cleaner.

No matter what I do or others, you are not going to change the direction of the EPA; it is too strong. You will have to work within their structure.
 
I hope you are talking to Robert. He is the one who refuses to work with us. We overwhelmingly asked him not to "shop" and to remove the new and overly restrictive "hot water" clause.

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Tony:

I did not create the "Hot Water Clause", the EPA Scientist did! I do not know for sure, but I think it was based on Oregon, San Francisco, and Miami/Fort Lauderdale Testing. This is the birth place of Mobile Cosmetic Cleaning Regulations.

I would like to take credit for everything you have alleged; but no one individual has that much influence on the EPA except the EPA Director and the President of the United States.

Sorry.
 
Nigel, if runoff could be gravity filtered so that no EPA listed contaminants made it to the storm drain and if you had a non toxic substance that would turn your sludge into an instant solid that could be disposed of in the dumpster would you turn your efforts towards that method and start putting your collected sludge in the dumpster instead of on youtube to frighten people with a visual that doesn't represent what we do?

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Tony:

If you have been following my videos then you would have seen where Gravity Filtration was proposed to about 40 Regulators including the EPA all of the way down to local municipalities. Their position was that this type of filtration was not designed for our industry. Even if we remediated our Wash Water to drinking water quality it could not go down the storm drain, period.

When I challenged this their answer was that Contract Cleaners were not a very professional group and they wanted every drop to be discharged to Sanitary Sewer.

After the meeting I got them to relent some and the result is the EPA's Cosmetic Cleaning Model Ordinance. Based on the statements you have made, I assume you have never read it. If you have read it then you need a refresher.
 
Happy New Year to everyone, be safe and no DWIs.
 
Tony:

Please read these reports then remake the above statements, they need correcting. Michael told you the truth, he was only involved in Fleets at the time, he was too busy building his business to over 100 employees and did not have the time to follow my activities.

He is still over 80% Contract Cleaner.

No matter what I do or others, you are not going to change the direction of the EPA; it is too strong. You will have to work within their structure.

I read the reports Robert. Unless I read it wrong it says the data was concentrated on fleetwashing. Did I miss something?

I do not believe it is too late.

Where is our advocate?

By this time in the evolution of our industry we should be looked upon as assets in our community like the street sweepers.

We should be showing them that frequent cleaning reduces or eliminates the need for soap and not trying to add more polluting power equipment to justify higher prices.

Confusion and fear tactics have led to customers cutting frequencies or cutting out cleaning altogether.

Why do you have presentations about how we must deal with runoff, but none about the vast benefits we offer society? Why are we presenting about filtration and not educating the AHJ's about systems already built in place and where their authorization ends (on property as long as it is not an imminent threat)





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Tony:

Please read these reports then remake the above statements, they need correcting. Michael told you the truth, he was only involved in Fleets at the time, he was too busy building his business to over 100 employees and did not have the time to follow my activities.

He is still over 80% Contract Cleaner.

No matter what I do or others, you are not going to change the direction of the EPA; it is too strong. You will have to work within their structure.


Its to bad that you feel this way Robert.
 
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