EPA Enforcement in 2012 Protects Communities From Harmful Pollution

Tony Shelton said:
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:

If you have read it, then you did not understand it.

It was based on input from about 100 contract cleaners representing all phases of the industry, including pressure washing, window cleaning, carpet cleaning, hazardous facilities, Grease Trap Services, and Painting Contractors. Fleet Cleaning was about 25% of those attending.

For a lot of stake holders pressure washing was side line to another business. About 25% Flat Work, 25% Truck Washing, 15% Kitchen Exhaust, 35% Other.

When I was a Contract Cleaner for 10 years I started out in Fleet Washing then moved into Building Restoration and gave away all of my Fleet Washing Accounts to other Contract Cleaners; about $50,000 per month of business, we had about 28 employees.

I sold the company because my wife complained that I had not had a day off for 9 months and did not know the day of week anymore.

I had a regulator feel sorry for me and took me under his wing and mentored me on the ways of the EPA and taught me thing that you would never learn from the outside. I founded PWNA as a result of his training and encouragement.

At one point I was under EPA Video Surveillance for 6 months because of all of the false rumors. I was told about it after the Surveillance was complete and they had determined that the accusations were false. They told me that normally I would not have been informed about the surveillance.

If you knew where we came from you would have a different outlook. In the early 90's the industry was totally shut down for a short period in San Francisco. Talk to anyone that survived that period.
 
junker1 said:
Its to bad that you feel this way Robert.
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Steven:

I can understand why you feel that way, but it is based on a lack of and miss information.
 
Robert Hinderliter said:
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.
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My local county (Howard) POTW AHJ was the least communicative and accommodating I have dealt with thus far, (they never returned my phone calls, for the most silly reason, but i eventually got a hold of them )

Howard County Maryland POTW mentioned that I can bring my wash water to the POTW onsite discharge point for disposal, if it met the parameters for discharge, no heavy sediment, pH limits (cant remember exactly so i dont want to enter) and FOG 100ppm limits.

They went on to say in a nutshell, "you verify the current local requirements for transportation".

The most interesting thing said was, "the sewer lines are designed for domestic wash water", there was no convincing the individual to hear what I had to say about wash water discharge from pressure washing of sidewalks or drive thru with pretreatment to the sanitary.

The crazy thing is they are incorrect, it is impossible to think that the county has no commercial operations that discharge directly or after pre treatment to sewer lines which lead to the POTW. I even sited that Marylands largest POTW (the WSSC) had implement BMP's for the discharge of the mobile contract cleaner.

The Storm Water Management AHJ for Howard county prefers the POTW alternative, because they prohibit direct discharge to the storm system or to its connecting components (ponds, basins, etc) even with pre treatment during mobile commercial cleaning. The SWM Authority has no jurisdiction, and major influence over/with the POTW.


This was not the case with Montgomery and Prince Georges Counties Maryland, the Department of Enviroment (DEP), was more influential in informing their county POTW's to put something in place that mobile contract cleaners can discharge to sanitary sewer.

After all, POTW's nation wide have developed programs for commercial kitchen wash water.

Howard County POTW is a hard nut to crack.
 
greg/sd said:
Eneryone should print that out and keep it in a binder on your rig.
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I DO, I was telling Tony about this last night. I have never been sited in 28 years, we carry them on each truck. Now my guys have the link in smart phone as well
 
Ron Musgraves said:
Steven here is the truth and the most Common Practice on the EPA own Website EPA SITE
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The line in red bold lettering written with, quote "reach waters of the united states"; how do you interpreted this? I can visualize it being interpreted various ways.

The problems I have when cleaning is how or what is the best practice to use to keep the wash water from reaching the "storm sewer system" as indicated in the article.

I have seen mentioned leave the water on property and never reach the storm, but in most cleaning situations I have, the extra volume of water utilized during cleaning that is not absorbed or evaporated wants to evacuate to the "storm sewer system" because of the properties gradient are designed to reduce flooding. What is the best way of handling this situation?

Edit:
1) Wanted to add that, I am aware that some US locals allow the runoff discharge of certain mobile cleaning to "storm sewer system" with a permit, my locals does not
 
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810f250 said:
The line in red bold lettering written with, quote "reach waters of the united states"; how do you interpreted this? I can visualize it being interpreted various ways.

The problems I have when cleaning is how or what is the best practice to use to keep the wash water from reaching the "storm sewer system" as indicated in the article.

I have seen mentioned leave the water on property and never reach the storm, but in most cleaning situations I have, the extra volume of water utilized during cleaning that is not absorbed or evaporated wants to evacuate to the "storm sewer system" because of the properties gradient are designed to reduce flooding. What is the best way of handling this situation?
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On that Nigel from what Robert taught is to use berms when you can and rinse onto landscaping when you can. If the AHJ's Show up and your trying to be compliant then you will probably be OK. If you just let the water run off property into a storm drain like a river and an AHJ come by that is a ticket writer... There could be problems. I'm not telling something you don't know and I understand why your putting that question out there. I'm interested as well to read other replies here on how they solve this problem.

Also I find your video's to be some of the most "informative" ones on the net. Especially when your doing experimental ones and take the time out to show us because video's can be time consuming. As always thanks for taking the time.
 
Clean County PW said:
On that Nigel from what Robert taught is to use berms when you can and rinse onto landscaping when you can. If the AHJ's Show up and your trying to be compliant then you will probably be OK. If you just let the water run off property into a storm drain like a river and an AHJ come by that is a ticket writer... There could be problems. I'm not telling something you don't know and I understand why your putting that question out there. I'm interested as well to read other replies here on how they solve this problem.

Also I find your video's to be some of the most "informative" ones on the net. Especially when your doing experimental ones and take the time out to show us because video's can be time consuming. As always thanks for taking the time.
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Actually John if the property is built to handle it with detention or retention you would never want to pollute the ground water by discharging into Landscape.

John that what your missing, no one is discharging off property.
 
ScreenShot2013-01-01at101414AM_zpsbc39ff27.png


19742 Germane Town Road


No water will ever Escape to the MS 4 US waters at that location. By LAW it is built compliant. Discharging into the grass there would be polluting, hauling water off would be increasing the liability of this owner. He paid money to have this system installed to keep him safe.

Any knuckle head picking up waste water here is a polluter unless they are permitted Licensed hauler to go directly to a pretreatment facility.


Welcome to the world of Ron Musgraves Enviro 101
 
Steven Button said:
So what's the (general) rule when washing a property whose on property goes to their own retention area? Does that count as US waterways?
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Florida EPA


Steven you should Attend these more than you realize when NCE comes , skip all the rest. DO NOT MISS THESE
 
Ron Musgraves said:
John that what your missing, no one is discharging off property.
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I think what your missing Ron because you don't go out in the field is the discharge can find it's way off property. You need to have preventative measures to keep that from happening as well even if the intentions were never to discharge off property.

You should go out in the field once in awhile and if your company does any large jobs that are just downright nasty take a look around to see where there wash water might end up flowing..

Just because it may flow off property I'm not suggesting that's what the contractor's intentions are.
 
Ron Musgraves said:
ScreenShot2013-01-01at101414AM_zpsbc39ff27.png


19742 Germane Town Road


No water will ever Escape to the MS 4 US waters at that location. By LAW it is built compliant. Discharging into the grass there would be polluting, hauling water off would be increasing the liability of this owner. He paid money to have this system installed to keep him safe.

Any knuckle head picking up waste water here is a polluter unless they are permitted Licensed hauler to go directly to a pretreatment facility.


Welcome to the world of Ron Musgraves Enviro 101
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A mobile cleaning operation should contact the local AHJ and obtain in writing that this installation can be used for commercial pressure cleaning wash water runoff, in my opinion.

Although it may appear obvious to a mobile cleaning operator who is aware of the EPA Region 6 wording and that it falls within the EPA's published guidelines, if the local AHJ says it cannot be used for such, it simply cannot be used for this purpose.

I can call and determine what is the AHJ's position on this installation.

The AHJ is who ensures that you will be in compliance within their local. Which in most cases I have experienced is on par with the EPA region 6 document or stricter
 
810f250 said:
A mobile cleaning operation should contact the local AHJ and obtain in writing that this installation can be used for commercial pressure cleaning wash water runoff, in my opinion.

Although it may appear obvious to a mobile cleaning operator who is aware of the EPA Region 6 wording and that it falls within the EPA's published guidelines, if the local AHJ says it cannot be used for such, it simply cannot be used for this purpose.

I can call and determine what is the AHJ's position on this installation.

The AHJ is who ensures that you will be in compliance within their local. Which in most cases I have experienced is on par with the EPA region 6 document or stricter
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WHY they have no Jurisdiction , give the numbers I'll call them and record the permission for you.
 
Clean County PW said:
I think what your missing Ron because you don't go out in the field is the discharge can find it's way off property. You need to have preventative measures to keep that from happening as well even if the intentions were never to discharge off property.

You should go out in the field once in awhile and if your company does any large jobs that are just downright nasty take a look around to see where there wash water might end up flowing..

Just because it may flow off property I'm not suggesting that's what the contractor's intentions are.
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John, watch the Video's study it hard you will get it one day.
 
Ron Musgraves said:
Florida EPA


Steven you should Attend these more than you realize when NCE comes , skip all the rest. DO NOT MISS THESE
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Never missed an NCE event in FL... I don't think?! We just didn't stay at the hotel at the last Tampa event.

Holly was at this presentation while I was at Russ J's class... I am clear on the no-off property discharge, just need to be sure that when using degreasers on certain hydrocarbon rich surfaces that we are good for discharge to their own retention area. We use oil socks where necessary.
 
Steven Button said:
Never missed an NCE event in FL... I don't think?! We just didn't stay at the hotel at the last Tampa event.

Holly was at this presentation while I was at Russ J's class... I am clear on the no-off property discharge, just need to be sure that when using degreasers on certain hydrocarbon rich surfaces that we are good for discharge to their own retention area. We use oil socks where necessary.
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Potatoes
 
Not every property is built like that Maryland property which looks like it's got it's act together. Most gas stations by me I don't see anything like that but then again we don't have any intentions in cleaning them so I haven't really looked t often on how they handle their discharge.

Also looks like what your video is showing is the water recapture areas is built in with the landscaping as the surrounding area... If your saying Ron that no discharge should ever go the landscape area's and it false for anyone to say that's even allowed then why don't these places like what you show on the video just have it where the pavement dips downwards towards drains all around the gas station pavement like they are in parking garages(be advised though that even in parking garages they don't have the tilt right where sometimes the water never even flows to there drains and it just puddles up)
 
Clean County PW said:
On that Nigel from what Robert taught is to use berms when you can and rinse onto landscaping when you can. If the AHJ's Show up and your trying to be compliant then you will probably be OK. If you just let the water run off property into a storm drain like a river and an AHJ come by that is a ticket writer... There could be problems. I'm not telling something you don't know and I understand why your putting that question out there. I'm interested as well to read other replies here on how they solve this problem.

Also I find your video's to be some of the most "informative" ones on the net. Especially when your doing experimental ones and take the time out to show us because video's can be time consuming. As always thanks for taking the time.
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Thanks John T, glad the videos were helpful.

This is a frequent situation that I face, and almost certain their are others with similar issues.
For example a great deal of properties have "storm drain" inlets in the drive thru, no avoiding runoff there from rain events or from mobile cleaning operations.

But the local AHJ do not allow mobile cleaners to allow produced runoff into these storm inlets, and I can imagine that they can issue a warning or fine to a property owner for the condition of the hard surface leading to the storm inlet.

Like mentioned earlier Walmart has install systems similar to what Ron has posted of the Maryland fuel station in their parking lots. I will post pic in thread when next i go out that way.
 
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