EPA rules for Mobile washers

I just have to follow what the FEDS say, if I can make this happen they can write re-write and dance around all they want. If I can make that happen its all that counts.

Jim, I got the feeling that you dont like what the feds are telling us? Its just to simple?

We should have a massive campaign to let pressure cleaning contractors around the world know.

You can keep throwing the rules and guidelines out there, your not getting that its so simple.

Wait let me post this one more time...

Thats not Ron Musgraves, is the federal goverment that makes the rules. Now your local people are being bamboosled.LOL

YOU ARE RIGHT RON, I do not agree with this AT ALL !!! But I as one man cannot stop it.

AGAIN, THIS IS NOT STATE WIDE nor for the entire Region 9. It is a request to change the requirements, nothing more. But I still do not like it.
 
YOU ARE RIGHT RON, I do not agree with this AT ALL !!! But I as one man cannot stop it.

AGAIN, THIS IS NOT STATE WIDE nor for the entire Region 9. It is a request to change the requirements, nothing more. But I still do not like it.

But if you can make this happen it means nothing

The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States. If your discharge does not reach waters of the United States, then there are no requirements under the CWA.
 
The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States. If your discharge does not reach waters of the United States, then there are no requirements under the CWA.
...seven more times maybe someone, just one person will get this.

Opps, it could not be that simple???? it is
 
But if you can make this happen it means nothing


It is my understanding that this is be law and that the current law you quote will be amended. This will affect your state as well.

What I understand is this,

1. you clean

2. water is evaporated Before it hits the storm drain

3. particles carried in the water get deposited in the gutter when the water get evaporated.

4. You must pressure wash the particles in the gutter and filter them so that when it rains, those particles do not go down the storm drain and into the waterways.

This is the basic procedure that they are requiring and is already in affect in many cities in Nevada and California. Both states are looking into this and possibly submitting it to the EPA for region 9 amendment, from what I am told.


AGAIN, I do not agree with this !!!

I will not work in the cities that do support this. The cost for pressure washing would increase.
 
YOU ARE RIGHT RON, I do not agree with this AT ALL !!! But I as one man cannot stop it.

AGAIN, THIS IS NOT STATE WIDE nor for the entire Region 9. It is a request to change the requirements, nothing more. But I still do not like it.

Jim, I've seen what you get at the bottom of a parking garage. There's a ton of oil. But even THAT could easily be filtered and sent down the sewer or the storm drain with no negative effects.

You've got the system, you corral the water, filter it then dump it.

It's all legal and clean. But what you are doing is a far cry from what we're seeing pushed on contractors that are using units that look like R2D2 with vacuum lines a hundred miles long using twice as much fuel for generators and twice as much air pollution to suck up a little bit of water and look like retards doing it!

The average Joe must shake his head in puzzlement as the street sweeper goes by spraying water and pushing dirt right into the drains as we frantically try to suck up every drop of water that I'd drink if I had to!!

All I'm saying is that if you are so on top of all this legislation, why not use some of your influence and experience to put in your 2 CENTS!! :D
 
It is my understanding that this is be law and that the current law you quote will be amended. This will affect your state as well.

What I understand is this,

1. you clean

2. water is evaporated Before it hits the storm drain

3. particles carried in the water get deposited in the gutter when the water get evaporated.

4. You must pressure wash the particles in the gutter and filter them so that when it rains, those particles do not go down the storm drain and into the waterways.

This is the basic procedure that they are requiring and is already in affect in many cities in Nevada and California. Both states are looking into this and possibly submitting it to the EPA for region 9 amendment, from what I am told.


AGAIN, I do not agree with this !!!

I will not work in the cities that do support this. The cost for pressure washing would increase.


No , how would you amend something that doesnt apply?
 
Jim, I've seen what you get at the bottom of a parking garage. There's a ton of oil. But even THAT could easily be filtered and sent down the sewer or the storm drain with no negative effects.

You've got the system, you corral the water, filter it then dump it.

It's all legal and clean. But what you are doing is a far cry from what we're seeing pushed on contractors that are using units that look like R2D2 with vacuum lines a hundred miles long using twice as much fuel for generators and twice as much air pollution to suck up a little bit of water and look like retards doing it!

The average Joe must shake his head in puzzlement as the street sweeper goes by spraying water and pushing dirt right into the drains as we frantically try to suck up every drop of water that I'd drink if I had to!!

All I'm saying is that if you are so on top of all this legislation, why not use some of your influence and experience to put in your 2 CENTS!! :D

You know buddy, I like your 2 cents !.

To answer your question, I HAVE TRIED. I EXPLAINED, I HAVE PLEADED TO DEAF EARS. All I get is " It is a long ways away before it happens.

Well after reading that letter for amendment, I am not so sure it is " A long way aways" . They explained that it is just an extra step.

We have to do this step when cleaning dumpsters and drive thru's. So they must think that it is not that big of a deal to put a vacuum at the nearest storm drain and push all the water filled with the particles to that vacuum to be filtered and sent to the sanitary sewer. An extra 15 minutes of set up.

Thats how you would have to do it. It really isn't that bad, BUT I STILL DO NOT AGREE WITH IT !!!
 
ok, I said all that I can.

I do not agree with this type of filtration cleaning for the sidewalks.

All I said is what was in writing or explained to me. I do not agree nor support this as I said in the last 6 posts.

Please guys do not take this as me supporting this.
 
ok, I said all that I can.

I do not agree with this type of filtration cleaning for the sidewalks.

All I said is what was in writing or explained to me. I do not agree nor support this as I said in the last 6 posts.

Please guys do not take this as me supporting this.


Jim,we support no discharge down a storm drain alos. We comply when needed. We avoid even being in this situation all together. Thats the part your missing, if you dont discharge to a US water. It does not apply like the epa says.

So they can re-write the code adopt BMP's. I will show them where ever they write them there silly code won't apply in 99.999999999999% of the time with my practice. When it does I will fully comply, more than even you Jim. We will be using hazmat permits and pretreatment facility.

This should make you burst a bubble, the way your doing it is not legal. I will challenge any of these BMP's if citys want to put ridiculous measures.

I will video tape record the stupidty of city personal giving 23 different answers to the same dump questions. Then send it to the city council for review. It worked in my city and 7 or 8 others.

By the way they have already done this in Cali a few years back, two guys started videotaping each other. Both got so many fines they are no longer here on the BBS. San Diego.


Alan & Jon knew the contactors, maybe they will chime in.
 
Just got off the phone with the SWRCQB. That amendment is for the Santa Rosa Area as a test. However it is losing support.

One Reason, to difficult to enforce.
 
Saved and added to the ammo camp. Thanks Ron. Does this apply to ALL regions or just Region 6.....alot of us are not Region 6.
 
presw.jpg


The most common method of compliance with the CWA is to prevent process wastewater discharges to waters of the United States. If your discharge does not reach waters of the United States, then there are no requirements under the CWA. Examples of compliance without a discharge are vacuuming up the process wastewater or berming the process water and allowing it to evaporate. An additional method of compliance is to discharge the water to an NPDES permitted sanitary sewer system (the municipality may have additional pretreatment requirements before accepting your discharge). The most common form of non-compliance is to discharge the process water into a storm sewer system or into a city street that drains to a storm water inlet. Most storm drainage systems in Region 6 discharge directly to waters of the United States without treatment, which means anything that discharges into a storm drain is the same as putting it directly into the waterbody receiving the storm drain discharge.
 
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